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.
The updated terms establish a new arrangement for USDC designated as 'Secured USDC' in connection with the Coinbase One Card. Under the revised language, if you designate USDC in your wallet as Secured USDC, you agree that Coinbase may transfer that amount to a third party designated as the secured party, and you will be restricted from withdrawing or transferring those funds. Additionally, the secured party's instructions to Coinbase regarding those assets take priority over any conflicting instructions you provide. The agreement states that you consent to all such permitted transfers. This arrangement operates independently of amounts owed to Coinbase, meaning Secured USDC will not be debited to satisfy debts you owe to Coinbase.
View change record →The updated terms eliminate language that previously allowed Coinbase to restrict your withdrawals if you designated USDC as Secured USDC and to comply with third-party secured party instructions without your consent. Under the revised agreement, Coinbase will not transfer, loan, or otherwise handle your Supported Digital Assets except as required by law or as you instruct. This means the One Card Secured USDC mechanism is no longer integrated into the core asset protection clause, and users no longer face withdrawal restrictions or loss of instruction authority tied to that designation. If you currently hold Secured USDC under a separate One Card cardholder agreement, that agreement remains in effect but is no longer cross-referenced in the main User Agreement's asset protection section.
View change record →The updated terms establish a new exception to the prior prohibition on transferring user digital assets. Previously, Coinbase stated it would not transfer assets except as required by law or per user instruction. The revised language now permits Coinbase to transfer USDC designated as 'Secured USDC' to third parties pursuant to a Coinbase One Card cardholder agreement. Users who elect to use this feature agree they will be restricted from withdrawing or transferring the secured portion, and they consent to Coinbase following instructions from a designated secured party without further user approval, even if those instructions conflict with the user's own orders to Coinbase. The full terms of this arrangement are stated to be in Appendix 4, which is not included in this summary.
View change record →Current version shifted from user acknowledgment of Coinbase's compliance obligations to user's own representation and warranty of legal compliance, and explicitly frames requirements as part of KYC verification process.
View full change record →This new provision shifts responsibility to users to affirmatively comply with AML/sanctions laws and restricts users from illegal activities, moving beyond prior KYC verification language to establish user obligations.
View full change record →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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Target reserves the right to change these Terms at any time. We will post notification of changes to these Terms on this page. Your continued use of the Target Services after any changes to these Terms constitutes your acceptance of the new Terms.
We reserve the right, at our sole discretion, to amend these Terms of Service at any time and will update these Terms of Service in the event of any such amendments. We will notify our Users of material changes to this Agreement, such as price changes, at least 30 days prior to the change taking eff...
We may modify the Terms from time to time. The most current version of the Terms will be located here. You understand and agree that your access to or use of the Service is governed by the Terms effective at the time of your access to or use of the Service. If we make material changes to these Terms...
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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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