By using Coinbase, you agree that Coinbase can request personal information and documents from you to comply with anti-money laundering and sanctions laws. You also agree not to use the platform for illegal activities including money laundering or terrorism financing.
This analysis describes what Coinbase's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The agreement requires users to cooperate with Coinbase's compliance requests, including providing identity documents and information on an ongoing basis. Failure to comply with these requests could result in account suspension or restriction under other provisions of the agreement.
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Coinbase may request identity verification documents, transaction information, or other materials from users at any time to comply with AML and sanctions obligations, and the agreement states that users must provide this information. Failure to respond to such requests could result in account restrictions under the account suspension provision.
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"You acknowledge that Coinbase is required to comply with applicable law and regulations, including those related to anti-money laundering and sanctions. You agree to provide Coinbase with such information and documentation as Coinbase may request, from time to time, in order for Coinbase to comply with these legal requirements. You agree not to use Coinbase Services in connection with any illegal activity, including but not limited to money laundering, financing terrorism, or other criminal activity.— Excerpt from Coinbase's Coinbase User Agreement
REGULATORY LANDSCAPE: User AML and sanctions compliance obligations engage the Bank Secrecy Act, FinCEN's Customer Due Diligence requirements, and OFAC's sanctions regulations. Coinbase operates as a money services business and is required to maintain a BSA/AML compliance program, which includes customer identification, transaction monitoring, and suspicious activity reporting. User cooperation with these requirements is a standard feature of financial services agreements. GOVERNANCE EXPOSURE: Medium. The provision's requirement for ongoing user cooperation with compliance requests creates a user obligation that, if not met, can trigger account restrictions. Institutional users should assess whether their own AML and KYC programs are consistent with the information Coinbase may request, and whether there are any restrictions on providing certain types of information to Coinbase under applicable privacy or data protection law. JURISDICTION FLAGS: International users may face conflicts between Coinbase's information requests and applicable data protection laws in their home jurisdictions, including GDPR in the EU. U.S. users are subject to FinCEN's CDD requirements and OFAC sanctions, which Coinbase's compliance program is designed to address. State-level AML requirements may also apply depending on the user's jurisdiction. CONTRACT AND VENDOR IMPLICATIONS: Institutional counterparties should assess whether the information-sharing obligations in this provision are consistent with their own privacy and data governance frameworks. Vendor assessments should evaluate Coinbase's data security practices for the user information collected under this provision. COMPLIANCE CONSIDERATIONS: Compliance teams using Coinbase for institutional purposes should document the types of information Coinbase may request and establish procedures for responding to compliance information requests. Legal teams should assess whether providing certain types of information to Coinbase creates any obligations or risks under applicable privacy law, including state privacy statutes.
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The agreement requires users to cooperate with Coinbase's compliance requests, including providing identity documents and information on an ongoing basis. Failure to comply with these requests could result in account suspension or restriction under other provisions of the agreement.
Coinbase may request identity verification documents, transaction information, or other materials from users at any time to comply with AML and sanctions obligations, and the agreement states that users must provide this information. Failure to respond to such requests could result in account restrictions under the account suspension provision.
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