Coinbase · Coinbase User Agreement · View original document ↗

AML/KYC Compliance Obligations

Medium severity Unique · 0 of 343 platforms
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Recent governance activity Coinbase recorded 4 documented changes in the last 30 days.
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Document Record

What it is

You are required to provide accurate identity information and Coinbase is required by law to verify your identity, monitor your transactions, and report suspicious activity to government authorities.

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)

Your transaction history and personal information may be shared with law enforcement or regulatory agencies without your direct knowledge if Coinbase determines reporting is legally required.

Recent Activity

This document changed recently

High May 15, 2026

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.

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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 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.

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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 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 →

Consumer impact (what this means for users)

This agreement significantly affects consumers by requiring mandatory binding arbitration and waiving the right to participate in class action lawsuits, limiting access to the traditional court system for disputes. Coinbase retains broad discretion to suspend or terminate accounts, freeze funds, and modify or discontinue services with limited notice, which can directly impact access to your digital assets. You can opt out of the arbitration clause by sending written notice to Coinbase within 30 days of first accepting the agreement, as detailed in the dispute resolution section.

Cross-platform context

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ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

Coinbase's AML/KYC program operates under FinCEN's Bank Secrecy Act requirements and applicable OFAC sanctions screening obligations. Compliance teams should note that Coinbase's SAR filing and transaction monitoring obligations may result in account restrictions or fund holds without prior notice to the customer.

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Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →
  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
May 5, 2026
Tracking information
First tracked
March 6, 2026
Last verified
March 9, 2026
Record ID
CA-P-00047006
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
7c35f81dd8060d5fd9689021eb84037242aabffeaecb2c92c503c4c285c72925
Analysis generated
March 6, 2026 20:10 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-P-00047006
Captured: 2026-03-06 20:10:18 UTC
SHA-256: 7c35f81dd8060d5f…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/amlkyc-compliance-obligations/
Accessed: May 31, 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/KYC Compliance Obligations clause do?

Your transaction history and personal information may be shared with law enforcement or regulatory agencies without your direct knowledge if Coinbase determines reporting is legally required.

Is ConductAtlas affiliated with Coinbase?

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