Gemini Dollar (GUSD) operates as an ERC-20 token on the Ethereum network, with its smart contracts undergoing audits by the security firm Trial of Bits Inc.
Private keys for signing transactions are stored offsite within secure, guarded, and geographically dispersed facilities using a cloud storage system. These keys reside on hardware security modules (HSMs) that comply with or surpass U.S. government computer security benchmarks, specifically FIPS 140–2 Level 3.
The system also employs multisignature (multisig) technology to enhance fault tolerance and provide an additional defense against attacks. Transferring funds from cloud storage requires multiple signatories, meaning that neither Tyler Winklevoss nor Cameron Winklevoss can move customer funds into or out of the hot wallet or cloud storage system, either individually or together.