gemini got spooked a couple years ago after they let barry silbert run their CEFI lending program and it went tits up
Discussion
Overcompliance
they're afraid of their users getting them in more trouble with the government. a person signs up for gemini using a stolen identity and bank account, then they start liquidating the proceeds from drug vending or phishing scams. gemini has to decide which outcome will make them lose more money. dealing with law enforcement whenever this happens, or turning off potential new customers who don't want to submit a stool sample.