Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': "The FTC may have jurisdiction over consumer harm arising from incorrect sanctions screening resulting in account freezes, particularly if Coinbase's screening processes are found to be deficient or its consumer notice procedures inadequate.", 'complaint_url': 'https://reportfraud.ftc.gov/'}, {'agency': 'CFPB', 'reason': 'The CFPB has UDAAP authority over practices that cause substantial consumer harm, including harm resulting from erroneous account freezes triggered by automated sanctions screening systems.', 'complaint_url': 'https://www.consumerfinance.gov/complaint/'}

What is the severity of this clause?

ConductAtlas classifies this OFAC Sanctions Compliance and Account Restriction clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

OFAC Sanctions Compliance and Account Restriction — Coinbase

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What it is

If Coinbase identifies your account as potentially connected to a sanctioned country or person — even if you're not — your account and funds can be immediately blocked with no advance warning.

Consumer impact (what this means for users)

Consumers, including US citizens and residents, face the risk of having their accounts and cryptocurrency holdings frozen immediately and without notice if Coinbase's sanctions screening systems produce a false positive match, with resolution potentially taking weeks or months through compliance review.

Cross-platform context

See how other platforms handle OFAC Sanctions Compliance and Account Restriction and similar clauses.

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Why it matters (compliance & risk perspective)

False positives in OFAC screening — where a legitimate user is incorrectly flagged — can result in sudden fund freezes with no immediate recourse, which is a documented risk with automated sanctions screening systems.

View original clause language

Coinbase is required to comply with economic sanctions programs administered by the Office of Foreign Assets Control (OFAC). By using Coinbase Services, you represent and warrant that you are not located in or a national or resident of a jurisdiction subject to OFAC-administered sanctions, and you are not on OFAC's Specially Designated Nationals and Blocked Persons List. Your account may be blocked or frozen if Coinbase determines that you are located in or are a national or resident of a jurisdiction subject to economic sanctions, or if you are otherwise on a restricted party list.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This provision reflects mandatory compliance with OFAC regulations under the International Emergency Economic Powers Act (IEEPA, 50 U.S.C. § 1701 et seq.) and the Trading with the Enemy Act (TWEA, 50 U.S.C. App. § 1 et seq.), administered through 31 C.F.R. Parts 500-598. Coinbase's OFAC obligations were highlighted in its 2023 settlements. The provision also engages FinCEN BSA/AML requirements for customer due diligence (31 C.F.R. § 1020.210).

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Applicable agencies

FTC

The FTC may have jurisdiction over consumer harm arising from incorrect sanctions screening resulting in account freezes, particularly if Coinbase's screening processes are found to be deficient or its consumer notice procedures inadequate.
File a complaint →
CFPB

The CFPB has UDAAP authority over practices that cause substantial consumer harm, including harm resulting from erroneous account freezes triggered by automated sanctions screening systems.
File a complaint →

Provision details

Document information

Document

Coinbase User Agreement

Entity

Coinbase

Document last updated

April 29, 2026

Tracking information

First tracked

April 27, 2026

Last verified

April 27, 2026

Record ID

CA-P-003283

Document ID

CA-D-00047

Evidence Provenance

Source URL

https://www.coinbase.com/legal/user_agreement/united_states

Wayback Machine

View archived versions →

SHA-256

516f4de6cc9bd5ec45d7bb576cc54d50e077ccea2137db72e7f96f02959c7d31

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Coinbase | Document: Coinbase User Agreement | Record: CA-P-003283
Captured: 2026-04-27 11:16:55 UTC | SHA-256: 516f4de6cc9bd5ec…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/ofac-sanctions-compliance-and-account-restriction/
Accessed: May 2, 2026

Classification

Severity

High

OFAC Sanctions Compliance and Account Restriction