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 reflects Coinbase's statutory obligation to implement sanctions compliance controls. The operational significance is that account restrictions may be implemented based on regulatory requirements rather than Coinbase's discretionary business decisions, and these restrictions serve to prevent violations of federal law that carry civil and criminal penalties.
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' accounts and funds may be blocked or frozen if Coinbase determines that continued access would violate OFAC sanctions regulations. The restriction mechanism is tied to regulatory compliance requirements rather than account terms violations.
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We may terminate or suspend your account and bar access to the Services immediately, without prior notice or liability, under our sole discretion, for any reason whatsoever and without limitation, including but not limited to a breach of the Terms.
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"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
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This provision reflects Coinbase's statutory obligation to implement sanctions compliance controls. The operational significance is that account restrictions may be implemented based on regulatory requirements rather than Coinbase's discretionary business decisions, and these restrictions serve to prevent violations of federal law that carry civil and criminal penalties.
Users' accounts and funds may be blocked or frozen if Coinbase determines that continued access would violate OFAC sanctions regulations. The restriction mechanism is tied to regulatory compliance requirements rather than account terms violations.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coinbase.