The U.S. District Court for the Southern District of New York denied a joint motion by the U.S. CFTC and crypto exchange Gemini to vacate their settlement, ruling that the $5 million civil settlement reached in early 2025 remains in effect.
After the change in administrations, the CFTC revisited its internal enforcement strategy and, in a rare move, joined the regulated platform in seeking to overturn an existing settlement and rescind the injunction against Gemini.
The presiding judge found that a shift in the regulator’s internal policy priorities or disputes over its predecessor’s enforcement actions did not provide a valid judicial basis for overturning a signed and effective legal settlement.
Although the $5 million penalty had already been paid in full and was nonrefundable, the court’s ruling makes clear that even if federal regulators take a more lenient stance, previously agreed administrative compliance obligations and injunctions cannot easily be undone.
After the change in administrations, the CFTC revisited its internal enforcement strategy and, in a rare move, joined the regulated platform in seeking to overturn an existing settlement and rescind the injunction against Gemini.
The presiding judge found that a shift in the regulator’s internal policy priorities or disputes over its predecessor’s enforcement actions did not provide a valid judicial basis for overturning a signed and effective legal settlement.
Although the $5 million penalty had already been paid in full and was nonrefundable, the court’s ruling makes clear that even if federal regulators take a more lenient stance, previously agreed administrative compliance obligations and injunctions cannot easily be undone.