Blair Halliday: Compliance is a key pillar of Gemini’s business

Gemini Europe, the UK and EU affiliate of the Winklevoss twins’ United States crypto exchange, has affirmed its commitment to compliance with the appointment of Blair Halliday as Chief Compliance Officer and Money Laundering Reporting Officer. 

Joining from the cryptocurrency platform Circle and bringing a wealth of experience with him to the role, we caught up with Halliday as his new position was confirmed. 

PaymentExpert: Firstly, can you tell us about your key focuses in the new role at Gemini? 

Blair Halliday: As Chief Compliance Officer at Gemini UK and Europe, my initial focus will be building on the outstanding compliance frameworks already in place, due to Gemini’s longstanding commitment to compliance and security which is a hallmark of the business, exemplified by Gemini being a New York Trust company regulated by the New York State Department of Financial Services (NYDFS). 

Those frameworks are a great starting point to expand on as we implement the controls required of an FCA authorised EMI, the license we are currently seeking from the UK’s regulators.

PE: Can you detail some of the ways in which Gemini is heightening its focus on compliance?

BH: Compliance has always been a key pillar on which Gemini has conducted its business activity. Entering into new markets will require the adoption and consideration of new local regulations for the business, and our compliance approach will focus on delivering those requirements within the UK, to continue the commitment to our regulatory responsibilities. 

Having both local and UK based compliance capability to supplement our colleagues in New York, provides a global perspective and oversight to protect our customers and provide reassurance to the regulators.

PE: Are you able to discuss some of the regulatory challenges that come with entering new markets?

BH: Whenever an organisation enters a new market, there are a number of challenges — education of the existing business, putting in effective controls, and understanding the risks that exist in that market. Companies struggle when there is a lack of local knowledge and/or assumptions are made. 

At Gemini we recognise these risks and have a Global Chief Compliance Officer (CCO) — Noah Perlman — who prior to joining Gemini ran Global Financial Crime for Morgan Stanley for 13 years, which included oversight of the European market. I have been hired as Gemini UK and Europe’s CCO to bring both EU regulatory knowledge, and having worked at Circle previously, an understanding of the risks and controls required for a crypto exchange.

PE: What do you predict will change in terms of compliance in the coming year?

BH: With the 5MLD now being enshrined in UK law, I think we will see businesses that are not prepared to adopt appropriate regulatory controls to their activities will continue to leave the UK and EU. 

With this, it provides companies like Gemini a great opportunity to demonstrate to the UK market the importance it places on adhering to regulatory requirements and to demonstrate Geminias a safe place for our customers to do business.

We are also seeing compliance and risk functions in traditional financial institutions looking at the crypto space, gaining a better understanding of the sector as their business development colleagues are seeing opportunities in the crypto sector. Part of our job is education and sharing best practice as the financial industry accelerates adoption.

PE: Lastly, can you tell us a little more about how Gemini is innovating within the industry?

BH: We have four pillars in our business — Compliance, Regulation, Security and Product— we will see innovation across these – whether from our new US$200m captive insurance business, Nakatomo; being the only exchange and custodian to complete a SOC 2 Type 2 security examination; or hiring senior banking professionals like Rob Cornish (CTO), Noah Perlman (CCO) and Julian Sawyer (MD Gemini UK and Europe). 

Our products continue to evolve and innovate. Gemini CustodyTM is leading the market in protecting our customers digital assets and our web and mobile app continue to improve to meet customer requirements. Gemini has some exciting plans, so more to come in 2020.