Coinbase · Coinbase User Agreement · View original document ↗

AML, Sanctions, and Regulatory Compliance Obligations on Users

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Recent Activity

This document changed recently

Medium May 2, 2026

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 wit…

Medium May 1, 2026

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 use…

Medium Apr 19, 2026

The updated User Agreement now includes explicit disclosures about virtual currency risks that apply to Connecticut residents and other jurisdictions. These disclosures state that virtual currency is…

Consumer impact (what this means for users)

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.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
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

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

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.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • CFPB
    The CFPB has oversight over financial product disclosures and practices related to customer due diligence and identity verification in consumer financial services
    File a complaint →

Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
May 12, 2026
Record ID
CA-P-011448
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3dc307b902ef1098b4f25d2d193ebebf46ef33ac6e1077fba19c28563a37eb5d
Analysis generated
May 9, 2026 19:59 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-P-011448
Captured: 2026-05-09 19:59:08 UTC
SHA-256: 3dc307b902ef1098…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/aml-sanctions-and-regulatory-compliance-obligations-on-users/
Accessed: May 13, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Coinbase's AML, Sanctions, and Regulatory Compliance Obligations on Users clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Coinbase?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coinbase.