The agreement requires users to comply with applicable laws and authorizes Coinbase to request additional identifying information and documents as part of AML and KYC compliance obligations before or during use of the platform.
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
This provision establishes Coinbase's authority to request identity and compliance documentation from users and to condition service access on completion of verification requirements, consistent with Coinbase's obligations as a registered money services business.
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 →Users are required to provide identity verification information and additional documentation as requested by Coinbase under AML and KYC requirements. Failure to provide required documentation may affect access to platform services.
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You agree not to post, upload, publish, submit or transmit any content that: (i) infringes, misappropriates or violates a third party's patent, copyright, trademark, trade secret, moral rights or other intellectual property rights, or rights of publicity or privacy; (ii) violates, or encourages any ...
You may not use our Services for any illegal purpose or in violation of any laws or regulations. You may not use the Services to send money to sanctioned countries or individuals on government watchlists. You may not use the Services for gambling, illegal drugs, weapons, or any other prohibited acti...
You may not automatedly crawl or query the Services for any purpose or by any means (including, without limitation, screen and database scraping, spiders, robots, crawlers and any other automated activity with the purpose of obtaining information from the Services) unless you have received prior exp...
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"Before you use our Services, you represent and warrant that you will comply with all applicable laws and regulations. We may require you to provide additional information and documents as part of our verification process, in accordance with our obligations under applicable anti-money laundering (AML) and know-your-customer (KYC) regulations.— Excerpt from Coinbase's Coinbase User Agreement
1) REGULATORY LANDSCAPE: This provision directly engages FinCEN's AML program requirements for money services businesses under the Bank Secrecy Act, OFAC sanctions compliance obligations, and applicable state money transmission licensing requirements that impose customer identification program standards. 2) GOVERNANCE EXPOSURE: Low to Medium. Identity verification requirements are standard for regulated financial services platforms, but institutional users should ensure that employees or account holders who use Coinbase on behalf of the organization are aware that personal identification information may be required and collected. 3) JURISDICTION FLAGS: OFAC sanctions compliance applies across all U.S. jurisdictions and affects users with connections to sanctioned countries or individuals. State-level customer identification requirements may impose additional obligations in certain jurisdictions. 4) CONTRACT AND VENDOR IMPLICATIONS: Institutional users should assess how identity and verification data collected by Coinbase is handled under Coinbase's privacy policy and whether collection of employee or representative identification data triggers internal data governance obligations. 5) COMPLIANCE CONSIDERATIONS: Compliance teams should ensure that identity verification processes are completed in a timely manner to avoid service interruptions, and should assess whether Coinbase's data retention practices for KYC documentation are consistent with internal data minimization policies.
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This provision establishes Coinbase's authority to request identity and compliance documentation from users and to condition service access on completion of verification requirements, consistent with Coinbase's obligations as a registered money services business.
Users are required to provide identity verification information and additional documentation as requested by Coinbase under AML and KYC requirements. Failure to provide required documentation may affect access to platform services.
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