To use Coinbase, you must provide your real identity and supporting documents, and Coinbase can request more information at any time if required by law or if they suspect any illegal activity connected to your account.
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 clause establishes Coinbase's operational framework for regulatory compliance with anti-money laundering and counter-terrorism financing obligations. It defines the conditions under which the platform may enforce enhanced due diligence procedures to satisfy legal and regulatory requirements.
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 →Removal of this specific KYC/AML verification provision and its replacement with broader user compliance obligations shifts the framework from Coinbase-imposed verification requirements to user-affirmed compliance responsibilities.
View full change record →Consumers must provide government-issued identity documents and financial information as a condition of service, and Coinbase may request additional documentation at any time — including during active account use — potentially freezing access to funds until verification is complete.
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"Before you are permitted to use the Coinbase Services, you must register for a Coinbase account and verify your identity. Coinbase may require you to provide additional information and documents at the request of any competent authority or in case of the application of any applicable law or regulation, including laws related to anti-laundering (money) or for counteracting financing of terrorism. Coinbase may also require you to provide additional information and documents in cases where it has reasons to believe that your transactions are connected to money laundering, terrorism financing, or other illegal activities.— Excerpt from Coinbase's Coinbase User Agreement
REGULATORY FRAMEWORK: This provision reflects obligations under the Bank Secrecy Act (31 U.S.C. § 5311 et seq.), FinCEN's Customer Identification Program rules (31 C.F.R. § 1020.220), FinCEN's 2013 virtual currency guidance (FIN-2013-G001), and OFAC's sanctions compliance requirements (31 C.F.R. Parts 500-598). The collection and retention of identity documents also implicates the CCPA (Cal. Civ. Code § 1798.100) for California residents, GLBA privacy provisions (15 U.S.C. § 6801 et seq.), and state biometric privacy laws (e.g., Illinois BIPA, 740 ILCS 14/1 et seq.) if biometric facial recognition is used in the verification process.
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The clause establishes Coinbase's operational framework for regulatory compliance with anti-money laundering and counter-terrorism financing obligations. It defines the conditions under which the platform may enforce enhanced due diligence procedures to satisfy legal and regulatory requirements.
Consumers must provide government-issued identity documents and financial information as a condition of service, and Coinbase may request additional documentation at any time — including during active account use — potentially freezing access to funds until verification is complete.
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