Gemini Teo
Part I · Thesis

Routing non-latency-critical U.S. enterprise workloads into Tier III Nepal colocation.

Gemini Teo LLC is a Delaware infrastructure advisory firm. We place U.S. AI-training, batch, archive, and back-office workloads into IFC-backed Tier III Nepal facilities — delivering material net savings against AWS baselines, with Delaware-law contracts, HIPAA, SOC 2, and GDPR-aligned safeguards.

$29M
IFC + Standard Chartered commitment to Nepal data infra (2025)
3,878 MW
Nepal installed capacity · 95% hydropower
50%
Share of 2026 U.S. data center builds delayed or cancelled
33
U.S. enterprise prospects in active pipeline
Part II · The opportunity

The U.S. grid cannot absorb hyperscale AI demand. Nepal can.

Meta, Alphabet, Microsoft, and Amazon are projected to spend approximately $700B in combined 2026 capex. Transformer lead times in the U.S. now run five years. Eleven gigawatts of announced capacity remains unbuilt.

Gemini Teo exists to relieve that bottleneck for enterprises whose workloads do not require sub-50-millisecond round-trip to North America. We route training runs, batch inference, disaster-recovery, archive, and back-office compute into vetted Tier III facilities in Nepal — where 2,456 MW of surplus hydropower is projected by FY 2025–26.


Part III · Precedent

U.S. enterprises have sourced technical labor and compute from Nepal for two decades.

The U.S.–Nepal technology corridor is not speculative. It is a mature, audited, regulated pathway already servicing the largest U.S. healthcare, analytics, AI, and fintech operators.

Cotiviti2004 · ~600 engineers · U.S. healthcare analytics
CloudFactory2010 · ~3,860 analysts · $78M funding
Leapfrog2010 · ~450 engineers
Deerwalk2009 · ~350 · Medicare work
Fusemachines2013 · ~500 professionals
LogPoint NepalSIEM · Cybersecurity

Nepal IT exports reached $515M in 2022 with 64% year-over-year growth. Domestic fintech processors F1Soft, eSewa, and Fonepay clear approximately $25B annually — a validation of Nepal's regulated payment and data infrastructure.

Part IV · Segment focus

Who this is built for.

Gemini Teo serves U.S. enterprises, asset-heavy mid-market operators, and institutional buyers whose compute demand has crossed what their existing U.S. infrastructure posture can deliver on lead time, unit economics, or carbon intensity. The fit-pattern is consistent: a technical sponsor with a defined workload profile, a procurement function that writes under Delaware law, and an enterprise governance track record that can clear HIPAA, SOC 2, and GDPR review.

Regulated verticals

Healthcare · financial services · insurance

Workloads that need HIPAA BAA, PHI handling, FFIEC-aligned controls, or insurance-grade audit trails. Batch inference, claims analytics, actuarial modeling, model retraining, and archive are the highest-fit profiles.

AI-native operators

Model training and batch inference

Frontier and mid-scale training runs, embeddings generation, synthetic data production, evaluation suites, and batch inference clusters. Sub-50-ms real-time serving is out of scope; everything above that latency threshold is eligible.

Asset-heavy mid-market

Energy · manufacturing · logistics

Simulation, digital twin, supply-chain optimization, telemetry archive, predictive maintenance, and disaster recovery. Typical engagement couples Saturn Dynamics advisory with Saturn Infra and Modeling placement.

Part V · Economic edge

Why the unit economics hold.

The placement arbitrage rests on four hard inputs, each independently observable and each independently auditable in the suitability memo we return to every prospective client.

Power price

~$0.05 / kWh

Delivered industrial power from a Nepal grid that is ~95% hydropower. Structurally below U.S. wholesale pricing in most ISOs and insulated from gas-price volatility.

PUE

1.32–1.38

Partner Tier III target efficiency. Cooler ambient temperature, water availability, and adiabatic cooling design drive the differential against U.S. median Tier III PUE.

Cooling

Adiabatic · hydropower-backed

Cooling cost is the second-largest Tier III operating line. Adiabatic plus hydropower-backed chilled-water plants compress cooling opex against U.S. equivalents, particularly in high-density AI racks.

Scope 2

~95% hydropower grid

For sponsors with SEC, California (SB 253 / SB 261), or EU CSRD disclosure obligations, routed workloads produce a measurably cleaner Scope 2 footprint than the U.S. national grid average.

Profile-specific net savings against AWS baselines are produced only inside the engagement-specific suitability assessment. No blanket savings figures are published on this website.

Saturn Infra and Modeling Pvt. Ltd.

Infrastructure brokerage delivery — the primary line.

We are not a colocation provider. We are the institutional conduit — structuring the partner relationship, the client contract, the compliance envelope, and the workload placement — between U.S. enterprise demand and Nepal Tier III supply.

Tier III certified partners DFI-backed 3.5 MW anchor 520 racks Kathmandu corridor 95% hydropower

Tier III. Uptime Institute Tier III indicates a concurrently maintainable site infrastructure — every capacity component and distribution path can be removed from service without impacting the IT load. Target availability 99.982%, redundant power and cooling paths, and maintenance windows that do not require workload shutdown.

Capabilities

What Saturn Infra and Modeling delivers.

01 · workload profiling

Suitability and placement modeling

Every candidate workload is profiled against latency tolerance, data residency, regulatory class, recovery-point objective, and egress economics. Only non-latency-critical workloads are placed.

02 · Partner underwriting

Tier III facility vetting

Ongoing commercial and technical diligence on Nepal's IFC-backed Tier III operators, with failover pathways across multiple facility operators.

03 · Contract structuring

Delaware-law MSA + SLA

Every engagement papered under Delaware law, AAA arbitration. Four-tier SLA breach framework with defined credits, remedy plans, and termination rights.

04 · Compliance envelope

HIPAA · SOC 2 · GDPR · CCPA

HIPAA Business Associate Agreement. SOC 2 Type II annual audit. GDPR Standard Contractual Clauses and DPA at engagement. CCPA / CPRA Service Provider Agreement. Nepal Privacy Act 2075 and Data Protection Act 2082 aligned.

05 · Cross-border operations

NRB, DIT, FITTA governance

Saturn Infra and Modeling registered under Nepal Companies Act 2063. Foreign investment approval under FITTA 2019. Listed with the Department of Information Technology. Currency flows routed per Nepal Rastra Bank regulation.

06 · 7-year NCA protection

Client and partner covenants

Client NCA under Delaware law. Partner NCA under Nepal law with NYC-seated arbitration. Pricing lock fixed for engagement term. Identity of infrastructure partner disclosed only under mutual NDA.

Operating model · engagement layer stack

How Saturn Infra and Modeling operates.

Saturn Infra and Modeling Pvt. Ltd. is not a reseller or a marketplace. Every engagement is constructed through a deliberate sequence of institutional layers. Each layer is contractually discrete, independently auditable, and signed under Delaware law. No layer is outsourced or optional.

01 · Sourcing

Demand qualification

U.S. enterprise engagements are originated by direct referral and institutional introduction. Every lead runs through written suitability screening before any infrastructure partner is engaged.

02 · Underwriting

Partner and workload vetting

Tier III partner diligence covers uptime history, financial standing, IFC backing, and regulatory status. workload vetting covers latency class, data residency, recovery objectives, and regulatory posture.

03 · Structuring

Delaware MSA · back-to-back partner paper

Client-facing contracts under Delaware law with AAA arbitration. Back-to-back partner agreements under Nepal law with NYC-seated arbitration. Seven-year non-circumvention protections on both sides.

04 · Placement

workload routing

Only non-latency-critical workloads are placed: training, batch inference, archive, back-office, disaster recovery, simulation. Each placement plan is documented with egress model and failover pathway.

05 · Compliance envelope

U.S. · EU · Nepal controls

HIPAA BAA, SOC 2 Type II, GDPR SCCs and DPA, CCPA / CPRA Service Provider Agreement, Nepal Privacy Act 2075 and Data Protection Act 2082. Independent audit annually.

06 · Governance & reporting

SLA · review · audit

Four-tier SLA breach framework. Monthly operating review. Quarterly executive review. Annual contract and compliance refresh. Every exception logged, remediated, and reported in writing.

Client disclosure policy

Active U.S. client identities are not published. Engagements are governed by reciprocal non-disclosure agreements with the offshore partner consortium and, in most cases, by explicit client confidentiality preferences. Named references are available under mutual NDA during advanced-stage diligence.

Book of business — defensible ranges

As an institutional-posture disclosure, Saturn Infra and Modeling's book of business is reported in defensible ranges rather than single-point figures. Current posture: 4–7 workloads under executed MSA; 40–55% anchor capacity committed, representing approximately 1.4–1.9 MW placed load; 10–16 workloads in suitability assessment; 3–5 MW in weighted near-term pipeline. Ranges are refreshed on a quarterly cadence and narrowed during engagement-specific diligence.

Capacity · present and forward

Built by Gemini Teo. Operated by Saturn Infra and Modeling.

Gemini Teo LLC is the development and capital-structuring vehicle for new Nepal data center capacity. Saturn Infra and Modeling Pvt. Ltd. is the in-country operator and commercial counterparty to U.S. enterprise clients. This separation preserves U.S. tax, contract, and arbitration posture while placing operating responsibility inside Nepal's regulatory perimeter.

Present · 2026

3.5 MW anchor · 520 racks

Tier III certified partner capacity in the Kathmandu corridor. 95% hydropower grid. IFC-backed operator. Capacity reserved for placed U.S. enterprise workloads under multi-year anchor commitments. Operated by Saturn Infra and Modeling under master services agreement.

Phase 2 · 2027–2029

10 MW pilot build

First purpose-built facility developed by Gemini Teo with blended capital from Foreign Direct Investment, IFC, and DFC channels, plus anchor-tenant pre-commitments. Tier III target. Operated by Saturn Infra and Modeling as commercial counterparty.

Phase 3 · 2029+

100 MW Saturn-owned

Tier III campus with senior debt from Standard Chartered and Nabil Bank. Developed by Gemini Teo. Owned and operated by Saturn Infra and Modeling. Multi-tenant anchor structure targeted at AI training, batch inference, and disaster recovery.

Phase 4 · 2035+

1–3 GW scale

Multi-gigawatt regional campus footprint. Institutional co-investment. Sovereign and development-finance participation anticipated. Transmission and grid interconnection structured under the Nepal Electricity Authority framework.

Forward-capacity figures reflect commercial intent based on demonstrated pipeline and regulatory posture. Build sequencing is subject to anchor-tenant commitments, capital formation, and regulatory approvals.

Strategic roadmap

Saturn Infra and Modeling — facility trajectory.

Saturn Infra and Modeling's commercial thesis is to grow from brokered colocation to anchor-tenant development to owned Tier III capacity, matching client demand growth and regional capital market maturity.

Phase 1 · 2026–2028
Brokerage
Colocation via vetted Nepal partners. 3–8 simultaneous U.S. clients.
Phase 2 · 2027–2029
10 MW pilot
Pilot facility development. FDI + IFC / DFC + anchor tenant pre-commits.
Phase 3 · 2029+
100 MW Saturn-owned
Tier III build. Standard Chartered and Nabil Bank senior debt.
Phase 4 · 2035+
1–3 GW
Multi-gigawatt scale. Institutional co-investment.
Saturn Infra and Modeling — SLA framework

Four-tier breach escalation. Contractual, not aspirational.

Level 1 · Minor

< 1% SLA miss

Automatic credit on next invoice. No remedy plan required.

Level 2 · Moderate

1–5% miss

Credit plus written root-cause analysis within 5 business days.

Level 3 · Critical

> 5% miss

Maximum credit plus mandatory remedy plan within 10 business days. Gemini Teo notified immediately.

Level 4 · Termination

Four critical in 12 months

Client may terminate on 30 days notice with full refund of current month plus one-month penalty.

Data breach: 2-hour notification, 24-hour written incident report, independent security audit within 30 days at Saturn cost, 3-month fee penalty for Saturn-caused breaches.

Saturn Dynamics Pvt. Ltd.

AI-led digital transformation and IT advisory — Kathmandu.

A Nepal-registered advisory delivering legacy-system modernization, cybersecurity, HR technology, and cross-border remittance architecture to mid-market enterprises in South Asia and the Gulf. The current flagship engagement is a six-year digital transformation program with one of South Asia's largest human resources organizations, streamlining HR, finance, and operations through data transformation and visualization consolidated into a Salesforce-integrated dashboard — replacing the manual, siloed information flows that continue to define most mid-market back offices.

Service lines

Advisory and delivery capabilities.

  • Omnichannel analysis of legacy systems — communications, data storage, company applications, HR
  • Cybersecurity and encryption engineering
  • Automation of sensitive file workflows
  • Data architecture and unified platform buildouts, Salesforce-integrated
  • HR technology implementation
  • Call center tooling and customer satisfaction instrumentation
  • Cross-border compliance and remittance frameworks

Work methodology

Agile delivery in two-week iterations. Each iteration closes on a demo and a signed milestone acceptance. Quarterly business reviews reconcile milestones to the annual engagement plan. Annual independent security audit. Documentation retained a minimum of seven years.

Architecture

The routing stack that moves a U.S. workload to a Nepal Tier III floor.

Every workload Gemini Teo places traverses a documented contract, technical, and compliance stack. The architecture is deliberately boring: proven components, single points of accountability at each hop, and a paper trail that satisfies procurement, security, privacy, and tax review on the U.S. side and Companies Act / FITTA / DIT / NRB review on the Nepal side.

Flow — U.S. enterprise to Nepal Tier III

  1. Enterprise ingress. Client-owned networks, private endpoints, or carrier-neutral meet-me points in U.S. hyperscale regions.
  2. MSA · DPA envelope. Delaware-law MSA; HIPAA BAA or GDPR SCCs where applicable; Nepal-side DPA under Privacy Act 2075 / Data Protection Act 2082.
  3. Gemini Teo routing layer. Identity, routing policy, workload suitability check, egress accounting.
  4. Transit. Redundant carrier paths (Mumbai, Singapore, Hong Kong) with 99.9%+ availability targets.
  5. Saturn Infra boundary. Contractual handoff to Saturn Infra and Modeling Pvt. Ltd. inside Nepal.
  6. Tier III colocation floor. Partner-operated Tier III facility, 95% hydropower grid, PUE 1.32–1.38.
  7. Audit. Monthly operational report, quarterly compliance report, annual independent security audit.

Cross-cutting planes

Identity
Client-federated SSO with short-lived credentials at every hop.
Data
At-rest encryption to FIPS 140-2 / 140-3; in-flight TLS 1.3 minimum.
Compliance
SOC 2 Type II annual · HIPAA BAA · GDPR SCCs + DPA · CCPA / CPRA SPA · Nepal DIT Directive 2081.
Observability
First-party metrics, tamper-evident audit logs, 7-year retention minimum.
Fig. 1 — End-to-end routing diagram
U.S. enterprise MSA · DPA Gemini Teo routing Transit Saturn Infra Tier III floor
Fig. 2 — Contract & compliance stack
Contract plane — Delaware MSA · HIPAA BAA · GDPR SCCs · CCPA / CPRA SPA · Nepal DPA Identity plane — client-federated SSO · short-lived credentials · least-privilege roles Data plane — FIPS 140-2/3 at rest · TLS 1.3 in flight · region pinning · tamper-evident logs Compliance plane — SOC 2 Type II · DIT Directive 2081 · Privacy Act 2075 · Data Protection Act 2082
Proprietary Facility

The Saturn-owned 3 MW pilot.

Gemini Teo is presently in active discussions with the Government of Nepal to secure a proprietary 3 MW Tier III facility on a dedicated site. The facility would operate as a Saturn Infra and Modeling-owned and -operated asset, underwritten by a combination of anchor-tenant pre-commits, FDI approval under FITTA 2019, and senior debt from Nepal commercial banks supported by DFI participation.

The 3 MW proprietary pilot is designed to move Saturn Infra and Modeling from a pure brokerage posture — placing U.S. workloads into partner-operated Tier III capacity — to an owned-capacity posture on a controlled site. Site selection criteria include: power-line adjacency, 95%+ hydropower mix, redundant fiber, seismic profile acceptable to Uptime Institute Tier III certification, and water-availability for adiabatic cooling that targets PUE 1.32–1.38.

The Government of Nepal engagement track runs through the Department of Industry (FITTA 2019 foreign direct investment approval), the Department of Information Technology (Data Centre and Cloud Services Directive 2081, Feb 2025), the Investment Board of Nepal where capital thresholds apply, Nepal Rastra Bank (foreign exchange inflow and outflow), and the Office of the Company Registrar (Companies Act 2063 filings). Independent Nepal counsel and auditor sign-off is procured at every stage; no informal commitments are made.

In parallel, Gemini Teo maintains a documented fallback. If the proprietary site track does not close on acceptable commercial terms, Saturn Infra and Modeling continues to route U.S. enterprise workloads into the partner-operated Tier III anchor capacity in the Kathmandu corridor — 3.5 MW, 520 racks, 95% hydropower, DFI-backed partner — under multi-year anchor commitments. The brokerage line stands on its own economics and is not contingent on the proprietary facility track.

This section exists so that principals reviewing Gemini Teo understand two things simultaneously: (1) the upside case — a Saturn-owned 3 MW Tier III pilot inside a well-understood Government of Nepal regulatory corridor, sequenced ahead of the 10 MW Phase 2 and 100 MW Phase 3 build — and (2) the base case — a partner-operated anchor that is already serving routed workloads today. The two-track posture is structural, not aspirational.

Governance · tax · ecosystem

Two jurisdictions. One contract stack.

Gemini Teo operates a deliberate U.S.–Nepal governance architecture: a Delaware LLC parent that structures every client contract, audit trail, and dispute pathway; and two Nepal private limited subsidiaries that operate entirely inside Nepal's Companies Act, FITTA, NRB, and DIT perimeter. Tax compliance runs on both sides under arms-length transfer pricing with independent counsel and auditor sign-off in each jurisdiction.

Delaware LLC · U.S. parent Nepal Companies Act 2063 FITTA 2019 NRB · DIT · IRD §482 transfer pricing Form 5471 · GILTI · FBAR
Entity architecture

Parent, subsidiaries, and chain of control.

Delaware parent

Gemini Teo LLC

Single-member Delaware Limited Liability Company registered 2025 under the Delaware LLC Act. All client MSAs, SOWs, DPAs, and BAAs executed at this level. Delaware choice-of-law and AAA arbitration seat on every engagement.

Nepal subsidiary · infrastructure

Saturn Infra and Modeling Pvt. Ltd.

Private limited company under Nepal Companies Act 2063. Foreign investment approved under FITTA 2019. Registered with the Department of Information Technology. Currency flows routed under Nepal Rastra Bank regulation.

Nepal subsidiary · advisory

Saturn Dynamics Pvt. Ltd.

Private limited company under Nepal Companies Act 2063. FITTA-approved foreign investment vehicle for AI and digital-transformation service delivery. DIT-listed IT and ITES service provider. Separate audit trail from the infrastructure vehicle.

U.S. tax posture

Filed, not avoided.

U.S. tax treatment is structured around the fact that both Nepal subsidiaries are Controlled Foreign Corporations of the Delaware parent. There is no bilateral U.S.–Nepal tax treaty in force; compliance therefore runs through standard Internal Revenue Code subchapter provisions rather than treaty relief. All positions are reviewed annually by U.S. tax counsel and an independent CPA firm.

Form 5471

CFC information return

Annual Category 4 / 5 filing for each Nepal subsidiary. Schedule J earnings and profits, Schedule P previously-taxed earnings, Schedule H current E&P. Substantial penalty exposure for non-filing — we do not carry that risk.

GILTI · Subpart F

Foreign income inclusion

Global Intangible Low-Taxed Income inclusion on Nepal subsidiary net tested income. Subpart F inclusions on any passive or tainted income categories. Modeled annually against §250 deduction and foreign tax credit posture.

§482 transfer pricing

Arms-length intercompany

All intercompany charges between Delaware parent and Nepal subsidiaries documented under IRC §482 and OECD guidelines. Contemporaneous transfer pricing study. Services priced on cost-plus or comparable uncontrolled transaction methods.

§250 · FDII posture

U.S. export income

Foreign-Derived Intangible Income deduction evaluated on qualifying U.S. export services to non-U.S. persons. Documentation and substantiation maintained at the Delaware parent level. No aggressive stance.

FBAR · FinCEN 114

Foreign account reporting

Annual filing on Nepal-held financial accounts exceeding $10,000 aggregate at any point in the reporting year. Delaware parent and U.S.-person signatories covered. Filed on calendar-year basis with the automatic extension.

Form 8938

FATCA asset disclosure

Specified foreign financial asset reporting on the Delaware parent's U.S. tax return. Coordinated with FBAR filings to ensure no reporting gaps. Reconciled to Nepal audited financials annually.

No tax-minimization strategy is marketed to clients. The pricing that reaches the client is net of Gemini Teo's fully compliant U.S. tax posture.

Nepal regulatory perimeter

Inside the law, not adjacent to it.

Companies Act 2063

Private limited formation

Both Nepal subsidiaries incorporated as private limited companies. Annual returns, audited financial statements, and director filings lodged with the Office of the Company Registrar.

FITTA 2019

Foreign investment approval

Foreign Investment and Technology Transfer Act approval obtained prior to capital inflow. Sector classification, minimum investment thresholds, and repatriation pathways defined per statute.

Nepal Rastra Bank

Capital account regulation

All inbound equity, outbound dividends, royalties, and technical service fees routed under NRB foreign-exchange circulars. Banking-channel documentation retained for every movement.

Department of Information Technology

IT service provider listing

Both entities listed with DIT as authorized IT / ITES service providers. Required for cross-border data-service engagements and for FITTA sector alignment.

Income Tax Act 2058

Corporate and withholding

Nepal corporate income tax applied to local net profits. Withholding tax on cross-border technical-service fees and royalties at statutory rates. Annual audit by ICAN-registered auditor.

Privacy & data protection

Acts 2075 & 2082

Nepal Privacy Act 2075 and Individual Data Protection Act 2082 controls on personal data. Coordinated with U.S. HIPAA, SOC 2, and EU GDPR controls at the engagement layer.

Market context

A mature U.S.–Nepal enterprise ecosystem.

Gemini Teo's cross-border thesis is not speculative. A documented generation of U.S. and international enterprises already runs meaningful production operations from Kathmandu — across healthcare analytics, cybersecurity, capital-markets data, and applied AI. Infrastructure brokerage is the natural next layer on a supply chain clients have already validated.

Cotiviti

U.S. healthcare payment integrity

One of Nepal's largest U.S.-owned enterprise employers. Payment-integrity and healthcare analytics delivered from Kathmandu for U.S. payer clients since 2016. Approximately 600 engineers in-country.

Deerwalk · Deerhold

U.S. healthcare analytics

U.S.–Nepal healthcare data-analytics platform with long-standing Kathmandu engineering operations. Demonstrated cross-border delivery of regulated healthcare workloads, including Medicare-adjacent work.

Fusemachines

Enterprise AI services

U.S.-headquartered applied-AI services firm with substantial Nepal engineering delivery. Operates exactly the AI-development and data-engineering workload profile that Saturn Infra and Modeling routes into Tier III capacity.

CloudFactory

Data labeling at scale

UK-incorporated, U.S.-serving data-workforce company operating large-scale Nepal delivery. Approximately 3,860 analysts; $78M in disclosed funding. Validates the talent depth for production AI and data operations.

Leapfrog Technology

U.S. enterprise software

U.S.-headquartered, Nepal-engineering model. Long-tenured delivery for U.S. fintech and SaaS clients under U.S.-law master services agreements — the same contractual posture Gemini Teo uses.

Verisk Nepal

Insurance analytics

Nepal operations of Verisk Analytics, a NASDAQ-listed data-and-analytics enterprise serving U.S. insurance and financial markets. Illustrates regulated-industry comfort with Nepal delivery.

F1Soft · eSewa · Fonepay

Financial technology at national scale

Nepal-domiciled fintech group clearing approximately $25B annually across domestic payment rails. Demonstrates local financial-services technical maturity — relevant for partner underwriting and banking channels.

LogPoint

Enterprise cybersecurity

European-headquartered SIEM and cybersecurity vendor with a Kathmandu engineering footprint. Illustrates regulated cross-border delivery within Nepal's existing infrastructure envelope.

Third-party enterprise references above are illustrative of Nepal's existing cross-border ecosystem. None are Gemini Teo clients or partners, and no affiliation is implied.

Advisor and auditor bench

Independent counsel on both sides of the structure.

U.S. corporate counsel
Delaware-admitted firm · engagement basis
U.S. tax counsel
Federal tax and international-tax specialist
U.S. CPA
Independent firm · annual review and filings
Nepal corporate counsel
ICAN / NBA-registered firm · Kathmandu
Nepal auditor
ICAN-registered auditor · annual statutory audit
Data protection counsel
HIPAA, GDPR, and Nepal 2075 / 2082 review

Named advisor and auditor identities are disclosed under mutual NDA during advanced-stage diligence.

Responsibility

Hydropower, not hydrocarbons.

Every workload routed through Saturn Infra and Modeling runs on a Nepal grid that is 95% hydropower. This is not a marketing posture. It is the structural basis on which the entire infrastructure thesis rests.

95%

Hydropower share

Of Nepal's installed generation mix. A fundamentally low-carbon grid — orders of magnitude cleaner than the U.S. national grid average.

2,456 MW

Projected surplus

Nepal hydropower surplus projected by FY 2025–26. This is the headroom that makes compute placement viable at scale.

3,878 MW

Installed capacity

Nepal Electricity Authority figure, 2026. Continues to grow with Upper Tamakoshi, Arun III, and other run-of-river installations.

The carbon argument

U.S. AI compute is overwhelmingly fossil-powered. Nepal's isn't.

Roughly 60% of U.S. electricity in 2025 came from fossil generation. Hyperscale data center expansion in the U.S. has materially slowed the retirement of coal and gas plants, and has accelerated the interconnection of new natural-gas capacity to meet AI demand.

Placing non-latency-critical workloads on a 95% hydropower grid — whose marginal unit is hydroelectric, not natural gas — produces a compute-carbon profile that institutional ESG frameworks can actually underwrite.


For enterprises with Scope 2 and Scope 3 disclosure obligations, Nepal-routed compute is not a workaround. It is the answer.
Community

The technology-corridor compact.

Gemini Teo's presence in Nepal is predicated on building the institutional capacity of the local engineering and compliance workforce. Saturn Dynamics trains the talent pipeline; Saturn Infra and Modeling anchors the enterprise demand. Both commit to annual transparency reports, long-tenured staff retention programs, and local-lawyer reviewed engagement documentation.

The compact extends beyond headcount. We commit to cross-border knowledge transfer: engineering, compliance, and procurement methods used at U.S. institutional scale are transferred to Nepal staff through documented training, paired delivery, and quarterly technical review. Graduates of the program are portable — credentialed to operate at the standard of any U.S. or European enterprise counterparty.

Environmental responsibility is not a marketing layer. The ~95% hydropower mix of the Nepal grid is the structural input to the Scope 2 story; PUE 1.32–1.38 at partner Tier III sites is the structural input to the direct energy story; adiabatic cooling and water-stewardship design are the structural inputs to the water-use story. Each input is independently verifiable in the partner's certification artifacts and in the Nepal Electricity Authority record.

Governance of the compact is two-sided. The U.S. parent accepts institutional accountability to its clients under Delaware law and U.S. regulatory review. The Nepal subsidiaries accept operational accountability to their employees, partners, and regulators under Companies Act 2063, FITTA 2019, DIT Directive 2081, NRB foreign-exchange rules, Privacy Act 2075, and Data Protection Act 2082. Neither side is asked to carry the other's obligations; both are documented.

Market thesis

Three structural signals.

Signal 1 · U.S. capex pressure

The $700B wall.

Combined 2026 capex across Meta, Alphabet, Microsoft, and Amazon is projected at approximately $700B. Amazon alone is guiding $200B+, sustaining AWS pricing pressure well into 2027.

Sources: company disclosures; Bloomberg; S&P Global.

Signal 2 · Grid constraint

30–50% build attrition.

30–50% of announced 2026 U.S. data-center builds are now delayed or cancelled. 11 GW remains announced but unbuilt. Transformer lead times in the U.S. approach five years.

Sources: Sightline Climate; Bloomberg; Wood Mackenzie; S&P Global.

Signal 3 · Nepal surplus

A 2,456 MW window.

Nepal installed capacity reached 3,878 MW in 2026, 95% hydropower. Surplus projected at 2,456 MW by FY 2025–26. IFC committed $29M to Nepal data infrastructure in July 2025, alongside Standard Chartered Bank Nepal.

Sources: Nepal Electricity Authority; IFC press; Standard Chartered Bank Nepal.

Regulatory credibility

The registrations and reviews underwriting the engagement.

Delaware + Federal U.S.

Gemini Teo LLC — Delaware registered. Client MSAs governed by Delaware law; AAA arbitration. Single-member disregarded entity for U.S. tax, flowing to the member's Form 1040.

Nepal regulatory

Nepal Companies Act 2063 · Office of the Company Registrar · Department of Industry (FITTA 2019) · Department of Information Technology (Nepal Data Centre and Cloud Services Directive 2081, Feb 2025) · Nepal Rastra Bank · Inland Revenue Department.

Data protection

Nepal Privacy Act 2075 · Nepal Digital Privacy and Data Protection Act 2082 — GDPR-aligned, 72-hour breach notification, Data Protection Officer required. Saturn Compliance Officer serves as DPO.

Cross-border tax

Each Nepal subsidiary triggers separate GILTI inclusion and Form 5471 filing. Transfer pricing documentation maintained between Gemini Teo LLC and each Saturn entity prior to material revenue flows. CPA-of-record for U.S.–Nepal cross-border filings.

Banking posture

Separate Nepali business banking at a major Nepal bank. Formal PAN and VAT registration. Public-facing company profile with OCR number and DOI approval visible.

Labor & contracting

Formal written contractor agreements demonstrating genuine independence — own tools, flexible schedule, multiple clients — to avoid misclassification risk. W-8BEN compliance where relevant for U.S. tax purposes.

Institutional posture
An IFC-backed Tier III infrastructure partnership, papered under Delaware law, delivered under Nepal corporate law, with a transparent compliance envelope that maps cleanly to enterprise procurement.
FAQ

Questions we receive from enterprise procurement.

Which workloads are suitable for Nepal placement?

Training runs, batch inference, long-tail archive, disaster-recovery, back-office compute, simulation workloads, and any workload without sub-50-millisecond round-trip latency requirements to North American end users. Consumer-facing real-time serving is not a candidate profile.

What governs the client contract?

Delaware law. All client Master Service Agreements are executed by Gemini Teo LLC in Delaware. Disputes resolve through AAA arbitration in the United States.

What compliance frameworks apply?

HIPAA BAA with Gemini Teo. SOC 2 Type II annual audit. GDPR SCCs and DPA at engagement. CCPA / CPRA Service Provider Agreement. Nepal Privacy Act 2075 and Nepal Digital Privacy and Data Protection Act 2082.

How is the Nepal infrastructure partner selected?

IFC-backed Tier III facilities only. Ongoing commercial and technical diligence with defined failover pathways. Identity of the specific partner is disclosed only under mutual NDA.

What does the SLA look like?

Four-tier breach framework — Minor, Moderate, Critical, Termination — with defined credits, remedy plans, and termination rights. Data breach notification within 2 hours, written incident report within 24 hours, independent audit within 30 days for Saturn-caused breaches.

How do I initiate an engagement?

A single-line reply from a principal or procurement lead at contact@geminiteo.com initiates a two-week suitability assessment. We will return a profile-specific suitability memo and a proposed engagement letter.

Knowledge Center

Daily signals on data centers, grid, capital, and policy.

A curated institutional briefing on the forces shaping our thesis: U.S. grid constraint, hyperscaler capex, Tier III supply, cross-border regulation, Nepal capacity, and capital flows. Refreshed on a rolling daily cadence. Every item is sourced, dated, and filtered for institutional relevance — not news volume.

Live feed Last refreshed · Editorial cadence · 1× daily, U.S. business-day
Precedent

The U.S.–Nepal technology corridor, in structural terms.

Nepal has been a regulated technology services corridor for the U.S. since 2004. The enterprises below have operated Nepal engineering, analytics, AI, and cybersecurity capacity at institutional scale for more than a decade.

Since 2004 · Atlanta-HQ

Cotiviti

Approximately 600 engineers in Nepal delivering U.S. healthcare analytics for 180+ payers including CMS and CDC work. Two decades of PHI-adjacent workflow precedent in-country.

Since 2010 · Durham-HQ

CloudFactory

Approximately 3,860 analysts in Nepal servicing U.S. AI training data pipelines. $78M in venture funding. Large-scale human-in-the-loop operations.

Since 2010 · Emeryville-HQ

Leapfrog

Approximately 450 engineers building custom software for U.S. enterprises from a Kathmandu base. Long-running delivery relationship with U.S. Series B / C startups.

Since 2009 · Boston-HQ

Deerwalk

Approximately 350 professionals delivering U.S. healthcare technology, including Medicare work. Multi-year federal-adjacent workflow experience.

Since 2013 · New York-HQ

Fusemachines

Approximately 500 professionals delivering AI engineering services from Nepal. Long-running U.S. enterprise and education-sector engagements.

Domestic · Nepal

F1Soft · eSewa · Fonepay

The domestic fintech stack clears approximately $25B annually across Nepal. Validation of regulated, NRB-supervised digital payment and data infrastructure.

Cybersecurity

LogPoint Nepal

SIEM engineering delivery. Nepal-based technical capacity supporting European and U.S. enterprise cybersecurity operations.

Trade volume

Nepal IT exports

$515M in 2022 · 64% year-over-year growth. Among the fastest-growing South Asian technology export markets, supported by DIT and FITTA-registered delivery entities.

Capital partners

U.S. and multilateral DFIs

Capital availability for Nepal Tier III data infrastructure is structural. The current baseline includes a $29M Nepal data-infrastructure commitment (July 2025) alongside Standard Chartered Bank Nepal, with multilateral and U.S. development-finance participation contemplated across Phase 2 and Phase 3 build financing.


These are third-party enterprises operating in Nepal, cited as market precedent. Gemini Teo is not affiliated with any of the listed enterprises. Figures are drawn from public disclosures and industry press as of 2025–2026.

Leadership

Kushal Guragain — Founder and Chief Executive.

Kushal Guragain is the founder of Gemini Teo LLC, and CEO of both Saturn Infra and Modeling Pvt. Ltd. and Saturn Dynamics Pvt. Ltd. He brings more than a decade of senior technology and product management experience across the healthcare and financial services sectors.

He currently leads a 32-person team at a U.S. Fortune 5 enterprise, where his remit services approximately 80 million U.S. consumers — an operating context that shapes the institutional posture, compliance rigor, and procurement-grade documentation that characterize Gemini Teo engagements.

Born in Nepal, educated through high school in India, and long settled in the United States, Kushal Guragain brings native fluency in the U.S.–South Asia corridor that Gemini Teo is built to operate. He holds a Bachelor of Science in Accounting from the University of South Florida, a Master of Science in Information Technology and Management, and a Master of Business Administration with a concentration in Leadership and Management.


Team

Principals.

KG

Kushal Guragain

Founder · CEO

Sets client strategy, executes U.S. engagements, leads cross-border structuring, monthly sign-off on consolidated operational and financial reports across both Saturn entities.

CTO · Resident Director (Nepal)

Appointment confirmed; name withheld pending disclosure approval

Directs all technical delivery and architecture decisions at Saturn Infra and Modeling and Saturn Dynamics. Biweekly sign-off on technical updates and client demos. Resident Director of record for Nepal regulatory filings under Companies Act 2063.

Entity structure

Flat. Deliberate.

Gemini Teo operates a flat two-subsidiary structure. A Delaware LLC parent signs every U.S. client contract. Two Nepal private limited subsidiaries operate entirely inside the Companies Act 2063, FITTA 2019, NRB, and DIT perimeter. Both subsidiaries flow to a single U.S. return under arms-length transfer pricing.

U.S. parent

Gemini Teo LLC

Delaware. Single-member disregarded entity for U.S. tax. Signs all client contracts under Delaware law. CEO: Kushal Guragain.

Infrastructure line

Saturn Infra and Modeling Pvt. Ltd.

Nepal subsidiary. Routes non-latency-critical U.S. enterprise workloads into Tier III Nepal colocation. CEO: Kushal Guragain. CTO and Resident Director appointed; name withheld pending disclosure approval.

Digital transformation line

Saturn Dynamics Pvt. Ltd.

Nepal subsidiary. AI-led digital transformation and IT advisory. Flagship engagement: six-year HR digital transformation with a major South Asian human resources organization. CEO: Kushal Guragain. CTO and Resident Director appointed; name withheld pending disclosure approval.

Milestones

Firm timeline.

2025

Delaware formation

Gemini Teo LLC registered in Delaware. Former name Vertex Global Advisory LLC converted to Gemini Teo LLC. Infrastructure thesis formalized.

2025

IFC + Standard Chartered commit $29M

Institutional capital anchor for Nepal Tier III data infrastructure established, underwriting the market entry thesis.

2026

Nepal subsidiaries

Saturn Infra and Modeling Pvt. Ltd. and Saturn Dynamics Pvt. Ltd. incorporated under Nepal Companies Act 2063. CTO and Resident Director appointed.

2026

Infrastructure pipeline

U.S. enterprise pipeline activated. HOT and WARM cohorts under structured outreach.

2027–2029

Phase 2 — 10 MW pilot

Pilot facility development initiated under FDI + IFC/DFC + anchor-tenant pre-commits.

2029+

Phase 3 — 100 MW Saturn-owned

Tier III build underwritten by Standard Chartered and Nabil Bank senior debt.

Careers

Building a high-trust execution team offshore.

Saturn Dynamics and Saturn Infra and Modeling operate as a high-trust execution team offshore. Our employees work directly on institutional-grade engagements, under documented governance, with cross-border visibility into U.S. client commitments. We screen deliberately and review every application personally.

Open role

Kathmandu · full-time

Director — Operations and Modality

Owns delivery operations across both Saturn entities. Builds and runs the execution modality that moves client engagements from suitability memo through milestone-accepted delivery. Partners directly with the CEO on U.S. enterprise commitments and with the CTO on technical cadence.

Strong candidates carry deep comfort with AI-assisted workflows, applied knowledge of data center operations or cloud infrastructure, and a documented record of running multi-party technology engagements under institutional governance.

Applications are reviewed within three U.S. business days. Qualified infrastructure, SRE, cybersecurity, data engineering, and compliance professionals with cross-border experience are also welcome to write to careers@geminiteo.com.

Contact

Begin a conversation.

Gemini Teo responds to substantive inbound from U.S. enterprise principals, procurement leaders, and allied institutional counterparties. We do not respond to unsolicited vendor outreach.

A single-line reply, indicating profile and workload context, is sufficient to initiate a two-week suitability assessment.


Registered office

Gemini Teo LLC
State of Delaware, United States

Nepal operations

Saturn Infra and Modeling Pvt. Ltd.
Saturn Dynamics Pvt. Ltd.
Kathmandu, Nepal

Response posture

Substantive inbound is acknowledged within one business-day operating cycle.

Preferred introduction channels

Gemini Teo prefers introductions that carry institutional context. The following channels move fastest:

  • A named procurement, infrastructure, or CFO-delegated lead at a U.S. enterprise.
  • A warm introduction from a mutual DFI, bank, or counsel relationship.
  • A prior client or investor referral identifying the workload profile.
  • A principal-level note at contact@geminiteo.com stating profile and scale.

We do not respond to unsolicited vendor pitches or generic marketing outreach.

Principal contact

For prospectus requests, mutual NDAs, and initial suitability inquiries.

Prefer direct email? contact@geminiteo.com · Careers: careers@geminiteo.com