The U.S. Commodity Futures Trading Commission (CFTC) has acknowledged that its 2022 lawsuit against Gemini Trust Company LLC was unjustified. In a joint application with Gemini, the CFTC sought a waiver of judgment for the case, which was settled in January 2025. A comprehensive review revealed that the lawsuit should not have been filed under current enforcement standards. Key issues included reliance on an unreliable whistleblower, questionable evidence against Gemini, and misuse of regulatory power to pressure a settlement.