Asset-Light Custody vs Gemini

This is really a story about business model shape, not just custody technology. Gemini runs custody inside a New York trust company and an exchange, which means more compliance staff, capital requirements, audits, and legal overhead have to scale alongside the product. BitGo and Fireblocks sell custody infrastructure and settlement rails to banks, ETFs, and fintechs, so they can add customers, chains, and transaction volume with a much more software-like cost base.

• Gemini is a New York limited purpose trust company and qualified custodian. That structure gives institutions comfort, but it also brings bank-like obligations and fixed operating costs that are harder to spread when institutional trading fees sit around 2 to 3 bps and custody is a smaller revenue line.
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• Fireblocks looks more like infrastructure software. Customers use its dashboards, policy engine, wallet APIs, and network of over 2,000 counterparties to move assets without Fireblocks needing to become the trading venue. That makes expansion into payments, tokenization, and embedded wallets faster than adding chartered entities market by market.
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• BitGo sits between the two. It is regulated custody, but its Go Network is built as settlement infrastructure for moving fiat and crypto 24/7 inside custody. Like Anchorage, it can win clients that want custody separated from exchange execution, but without Gemini having the same neutrality problem because Gemini also sells trading.
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The market is moving toward custody as embedded infrastructure inside ETF issuers, banks, brokers, and stablecoin payment flows. That favors providers that can plug into many partners without carrying the full operating weight of an exchange plus trust company, which is why Gemini's next growth step increasingly depends on turning regulation into a premium product rather than simply a moat.