Willow Crypto FAQ

Info & FAQ


Willow Crypto charges a 1%* annual management fee that is accrued daily and billed in arrears at the end of each month. 


Blockchange.ai, our TAMP who makes this service possible, charges a maximum of 1% annual management fee that is accrued daily and billed in arrears at the end of each month. As we grow, this fee is reduced for all clients.


Gemini Trust Company, our custodian, charges an execution fee of  0.35% or less –  for total portfolio buildout, tiered by volume rather than AUM and is transactional rather than on an annual basis. This fee also goes down for clients as our volume increases. Gemini also charges $300/yr for custody of IRA accounts with IRA Financial. 


Assuming portfolio turnover stays low, you would be charged an average annual fee of 2.35% (compared to 2.5% for similar publicly available but less comprehensive services).


*This fee is negotiable. 


U.S. dollars in your Gemini Account are eligible for FDIC insurance, subject to applicable limitations. Please see the FDIC Insurance section of Gemini’s User Agreement for more information.


U.S. dollar deposits in your Fiat Account held in one or more Omnibus Accounts at one or more Banks located in the United States are held with the intention that they be eligible for Federal Deposit Insurance Corporation (“FDIC”) “pass-through” deposit insurance, subject to the Standard Maximum Deposit Insurance Amount per FDIC regulations (currently $250,000 per eligible Gemini Customer) and other applicable limitations. Gemini's policy is to comply, in good faith, with the regulations and other requirements of the FDIC for pass-through deposit insurance, including those contained in 12 C.F.R. § 330.


Please note: Non U.S. dollar deposits held at any Banks or financial institutions, as well as U.S dollar deposits held at Banks or financial institutions located outside of the United States, may not be subject to or eligible for FDIC deposit insurance.


Certain circumstances may require Gemini to transfer fiat currency between two or more of their Omnibus Accounts or terminate their relationship with one of their Banks.


Movements of fiat currency between Omnibus Accounts are recorded in detail and will not affect the available balance in the Fiat Account of your Gemini Account or jeopardize the availability of FDIC insurance, subject to applicable limitations.



Gemini maintains insurance coverage for the digital assets that they hold on your behalf in their online hot wallet. Please see the Digital Asset Insurance section of their User Agreement for more information.


Our custodian ,Gemini, maintains commercial crime insurance for Digital Assets custodied in trust on your behalf in their online hot wallet (“Hot Wallet”). Gemini’s insurance policy is made available through a combination of third-party insurance underwriters.


Gemini’s policy insures against the theft of Digital Assets from their Hot Wallet that results from a security breach or hack, a fraudulent transfer, or employee theft.


Gemini’s policy does not cover any losses resulting from any unauthorized access to your User Account. You agree and understand that you are solely responsible (and you will not hold us responsible) for managing and maintaining the security of your User Account login credentials and any other required forms of authentication, including your API keys.


Digital Assets are not legal tender and are not backed by any government. Digital Assets are not subject to Federal Deposit Insurance Corporation (“FDIC”) or Securities Investor Protection Corporation protections. Please see the ‘FDIC Insurance’ section for more information on FDIC “pass through” insurance as it relates to your Fiat Account.


Willow Crypto uses Gemini Trust Company, a regulated New York State Trust Company and qualified custodian, to custody all of its digital assets.

Gemini is a fiduciary and qualified custodian under New York Banking Law and is licensed by the State of New York to custody digital assets. Gemini Custody™ is regularly audited and subject to the capital reserve requirements and compliance standards of a traditional financial institution.

Learn more about our custodian here.


Blockchange values the digital assets for fees on a daily basis. The exchange rate used is the CCCAGG method from CryptoCompare which is the conversion used throughout the site. Gemini rates are used specifically when we are executing trade orders.


We are able to open the following account types:

  • Individual Accounts
  • Joint Accounts
  • Trust Accounts
  • IRA (Traditional & ROTH) Accounts


A major benefit of the Separately Managed Account (SMA) model is that the investor gains direct ownership of asset. In our case, the investor gains direct ownership of their digital assets. This is in contrast to other vehicles like ETFs, mutual funds, or ETNs that may hold digital assets where your money is pooled with other investors and you do not get access to the potential tax benefits of direct ownership. The potential tax benefit is that you control the capital gains of the asset, which is more efficient to manage than being in a pooled investment which you assume when first invested. Please call us to discuss in more detail.


We explore various risks in our Risk Disclosure form located here. Please read and contact us with any questions or need for clarification.


Please note the following risks in accessing or using Gemini:

  • The risk of loss in trading Digital Assets may be substantial and losses may occur over a short period of time;
  • The price and liquidity of Digital Assets has been subject to large fluctuations in the past and may be subject to large fluctuations in the future;
  • Legislative and regulatory changes or actions at the state, federal, or international level may adversely affect the use, transfer, exchange, and value of Digital Assets;
  • In your jurisdiction, Gemini may not be regulated as a financial institution;
  • Deposits into your Digital Asset Account and your Fiat Account may not be considered deposits under the applicable laws, rules, or regulations in your jurisdiction;
  • Fiat currency in the Fiat Account of your Gemini Account may not be subject to applicable deposit insurance protection;
  • Digital Assets in the Digital Asset Account of your Gemini Account are not subject to deposit insurance protection, including, but not limited to, FDIC insurance or Securities Investor Protection Corporation protections;
  • Digital Assets are not legal tender and are not backed by the government;
  • Transactions in Digital Assets may be irreversible, and, accordingly, losses due to fraudulent or accidental transactions may not be recoverable;
  • Some Digital Asset transactions shall be deemed to be made when recorded on a public ledger, which is not necessarily the date or time that you initiated the transaction;
  • The value of Digital Assets may be derived from the continued willingness of market participants to exchange fiat currency or Digital Assets for Digital Assets, which may result in the potential for permanent and total loss of value of a particular Digital Asset should the market for that Digital Asset disappear;
  • The nature of Digital Assets may lead to an increased risk of fraud or cyber attack, and may mean that technological difficulties experienced by Gemini may prevent the access to or use of your Digital Assets; and
  • Any bond or trust account maintained by Gemini for the benefit of our Users may not be sufficient to cover all losses due to theft or fraud incurred by Users.

Additional information can be found here.


Our custodian’s BSA/AML Program is guided by the BSA, specifically, the AML and Counter-Terrorist Financing (“CTF”) provisions, as mandated by U.S. federal law, the Patriot Act, and all other rules and regulations regarding AML and CTF. These standards are designed to prevent the use of Gemini for money laundering or terrorist financing activities. We take compliance very seriously and it is our policy to take all the necessary steps to prohibit fraudulent transactions, report suspicious activities, and actively engage in the prevention of money laundering and any related acts that facilitate money laundering, terrorist financing, or any other financial crimes.


Patriot Act Notification

Please also note that Section 326 of the USA PATRIOT ACT requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account. This federal requirement applies to all new users. This information is used to assist the United States government in the fight against the funding of terrorism and money-laundering activities.

What this means to you: when each person opens an account on Gemini, we will ask each person for his or her name, physical address, mailing address, date of birth, and other information that will allow us to identify him or her.


Background Checks

In furtherance of our BSA/AML Program, we reserve the right to require you to provide us with additional information and/or require you to undergo a background check prior to being authorized to use Gemini, or at any point thereafter, in accordance with Applicable Laws and Regulations.


Source of Funds

You are not allowed to receive funds in your account from a sender other than yourself. Any funds you receive from a sender other than yourself will be considered unauthorized. We reserve the right to investigate the source of any funds in your account and determine, in our sole discretion, how to handle their disposition. Following our review of any funds in question and the circumstances by which you received them, we may determine that you are not the owner of such funds. If such a determination is made, we reserve the right to dispose of these funds in accordance with Applicable Laws and Regulations and in our sole discretion, which may include, returning them to the destination of their origin or to a charity of our choosing.


Sanctions Programs

Pursuant to the economic sanctions programs administered in the countries where we conduct business, including, but not limited to, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), we are prohibited from providing services or entering into relationships with certain individuals and institutions. In the event that we are required to block funds associated with your account in accordance with a sanctions program, or other similar government sanctions programs, we may: (i) suspend your account; (ii) terminate your account; (iii) return funds to the destination of their origin or to an account specified by authorities; or (iv) require you withdraw funds from your account within a certain period of time. We are not responsible for any losses, whether direct or indirect, that you may incur as a result of our complying with Applicable Law and Regulations, the guidance or direction of any regulatory authority or government agency, or any writ of attachment, lien, levy, subpoena, warrant, or other legal order.


For more information click here.


Our custodian has institutional-grade security with 24/7 access-controlled secured facilities. The hardware security modules that store the keys (what you need to access the coins) are kept entirely offline. Our custodian Gemini’s hardware security modules have achieved the highest levels of the U.S. government’s security rating.


In order to protect clients’ crypto-assets, Gemini has also instituted internal controls that restrict the ability for any assets to move between unauthorized accounts or parties. Specifically, any withdrawals or asset movement require real-time multi-signature authentication, two-factor authentications, and time-limited approvals.


You can read more about Gemini's security procedures here.