Coinbase · Coinbase User Agreement · View original document ↗

OFAC and Sanctions-Based Account Restrictions

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Recent governance activity Coinbase recorded 9 documented changes in the last 30 days.
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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)

OFAC-driven account freezes can occur without advance warning and without any wrongdoing on your part, potentially locking you out of your funds if Coinbase determines a sanctions-related concern exists.

Recent Activity

This document changed recently

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 wit…

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 use…

Medium Apr 19, 2026

The updated User Agreement now includes explicit disclosures about virtual currency risks that apply to Connecticut residents and other jurisdictions. These disclosures state that virtual currency is…

Consumer impact (what this means for users)

The agreement states that Coinbase may suspend, restrict, or terminate accounts and limit access to funds at its discretion, which could affect a user's ability to access their cryptocurrency holdings during volatile market conditions. The terms authorize a mandatory individual arbitration process and prohibit class action lawsuits, meaning users who have disputes with Coinbase must resolve them individually through arbitration rather than through court proceedings. You can opt out of the mandatory arbitration clause by sending written notice to Coinbase's legal department within 30 days of first accepting the agreement or within 30 days of receiving notice of a material change to the arbitration terms.

How other platforms handle this

Revolut Medium

If you do not have a social security number you may still be eligible to open a limited Revolut personal account. Depending on your immigration status, we may ask you to provide us with a copy of your supported U.S. visa and may limit your access to certain products and features.

Lime Medium

Lime reserves the right to (a) modify or discontinue, temporarily or permanently, the Services (or any part thereof); (b) refuse any user access to the Services for any reason, including if Lime believes that user has violated this Agreement; at any time and without notice or liability to you or to ...

Segment Medium

Twilio may, without notice, suspend or terminate Customer's account and access to the Services if Customer violates this Agreement, including the Acceptable Use Policy, or if Twilio reasonably believes that Customer's use of the Services is causing harm to Twilio, its network, or third parties.

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▸ View Original Clause Language DOCUMENT RECORD
"
Coinbase is required to comply with the laws of the United States including regulations administered and enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC). OFAC's regulations prohibit U.S. persons from transacting with individuals and entities in certain countries or with certain designated individuals. Failure to comply with OFAC regulations may result in civil and/or criminal penalties. In order to comply with applicable law, Coinbase may be required to block or freeze access to your account and the funds held within it.

— Excerpt from Coinbase's Coinbase User Agreement

Applicable regulations

CFAA
United States Federal

Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
May 5, 2026
Tracking information
First tracked
May 9, 2026
Last verified
May 12, 2026
Record ID
CA-P-007544
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
3dc307b902ef1098b4f25d2d193ebebf46ef33ac6e1077fba19c28563a37eb5d
Analysis generated
May 9, 2026 19:59 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-P-007544
Captured: 2026-05-09 19:59:08 UTC
SHA-256: 3dc307b902ef1098…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/ofac-and-sanctions-based-account-restrictions/
Accessed: May 13, 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 OFAC and Sanctions-Based Account Restrictions clause do?

OFAC-driven account freezes can occur without advance warning and without any wrongdoing on your part, potentially locking you out of your funds if Coinbase determines a sanctions-related concern exists.

Is ConductAtlas affiliated with Coinbase?

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