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 updated terms establish procedures for handling protocol upgrades and define Coinbase's role in migrating customer assets to new versions. Under the revised language, by maintaining a Coinbase account, customers are deemed to have instructed Coinbase to conduct Coinbase Supported Migrations on their behalf at times and in manner Coinbase solely determines appropriate. The agreement further states that Coinbase shall not be liable or responsible for any loss resulting from inability to transfer Digital Assets during a migration or from the Asset Transformation itself. This expands Coinbase's authority to act without advance notice while eliminating liability for migration-related losses.
View change record →The updated terms now explicitly disclose Coinbase's fee structure for California residents, establishing a $10 maximum fee for transactions under $200 and a 6% maximum for larger transactions, though actual fees displayed at checkout may be lower based on payment method, order size, market conditions, and location. The revised agreement also clarifies that virtual currency transactions may be irreversible and provides links to procedures for reporting unauthorized transactions, updating contact information, and accessing transaction receipts. Coinbase commits to providing California residents at least 14 days' prior notice of material changes to fees or terms affecting their accounts.
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 →How other platforms handle this
comply with Applicable Laws administered by the U.S. Commerce Bureau of Industry and Security, U.S. Treasury Office of Foreign Assets Control or other governmental entity imposing export controls and trade sanctions...
You must comply with all domestic and international export laws and regulations that apply to the software and/or Services, which include restrictions on destinations, end users, and end use.
goods licensed or sold on the Walmart Sites...are subject to the customs and export control laws and regulations of the United States of America...and you agree to comply with all applicable laws.
"your Company has implemented ongoing customer sanctions screening against applicable Sanctions Regimes lists and that your Company will not instruct or otherwise cause Coinbase to hold any assets or engage in any transaction that would cause Coinbase to violate applicable AML and Sanctions Laws...Excerpt from Coinbase's User Agreement
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The clause states: “your Company has implemented ongoing customer sanctions screening against applicable Sanctions Regimes lists and that your Company will not instruct or otherwise cause Coinbase to hold any assets or engage in any transaction that would cause Coinbase to violate applicable AML and Sanctions Laws...”
ConductAtlas has identified this type of provision across 182 platforms. See the full comparison.
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