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 the operational framework through which Coinbase fulfills regulatory obligations under anti-money laundering and know-your-customer requirements. The clause authorizes the company to condition service access and functionality on completion of verification procedures and to modify service parameters based on verification outcomes.
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 complete identity verification procedures as a condition of accessing Coinbase Services, and must provide requested information for fraud and financial crime detection. Continued access to services and the limits applicable to account activity may be modified based on verification information collected at account inception and on an ongoing basis.
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"You agree to provide us with the information we request for the purposes of identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime and permit us to keep a record of such information. You will need to complete certain verification procedures before you are permitted to use the Coinbase Services and your access to one or more Coinbase Services, and the limits that apply to your use of the Coinbase Services, may be altered as a result of information collected on an ongoing basis.— Excerpt from Coinbase's Coinbase User Agreement
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This provision establishes the operational framework through which Coinbase fulfills regulatory obligations under anti-money laundering and know-your-customer requirements. The clause authorizes the company to condition service access and functionality on completion of verification procedures and to modify service parameters based on verification outcomes.
Users are required to complete identity verification procedures as a condition of accessing Coinbase Services, and must provide requested information for fraud and financial crime detection. Continued access to services and the limits applicable to account activity may be modified based on verification information collected at account inception and on an ongoing basis.
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