Opening Summary
The SEC’s complaint against Genesis Global Capital and Gemini Trust Company related to the Gemini Earn program continues to advance in the Southern District of New York.
What Happened
According to SEC on February 15, 2026 in Federal — S.D.N.Y., The SEC’s complaint against Genesis Global Capital and Gemini Trust Company related to the Gemini Earn program continues to advance in the Southern District of New York. The primary source is linked in the Source section below; readers are encouraged to review it directly for full context.
Why This Is Trending Now
The case shapes the regulatory perimeter for retail crypto lending programs.
Why Businesses Should Pay Attention
Product structuring, disclosures, and custody arrangements are being reassessed industry-wide.
Practical Considerations
Businesses may want to monitor the status of the underlying rule, filing, proceeding, or announcement as it evolves. Companies may need to evaluate how this development could interact with current contracts, licenses, disclosures, and compliance programs. The issue may raise questions around vendor obligations, reporting timelines, and internal policy updates that warrant discussion with qualified counsel.
Cogent Law Perspective
Cogent Law helps digital-asset lenders and platforms structure programs that reduce SEC and state exposure. The best next step is to speak with counsel about the facts specific to your organization.
Key Takeaways
- The case shapes the regulatory perimeter for retail crypto lending programs.
- Product structuring, disclosures, and custody arrangements are being reassessed industry-wide.
- Cogent Law helps digital-asset lenders and platforms structure programs that reduce SEC and state exposure.
- Review the primary source from SEC for the full record before making any decisions.
- Speak with Cogent Law to discuss how this development may affect your business.
Related Practice Areas
FinTech, Blockchain & Cryptocurrency
Product, licensing, and regulatory work for fintech, crypto, and payments companies.
Learn MoreLitigation & Dispute Resolution
Commercial litigation, regulatory enforcement, and dispute resolution.
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Legal Disclaimer
This update is provided for general informational purposes only and does not constitute legal advice. Reading this update does not create an attorney-client relationship. For advice regarding a specific matter, please contact Cogent Law.



