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.
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 provision establishes the operational requirement for Coinbase to enforce sanctions compliance as a condition of service provision. This reflects the company's legal obligation under U.S. law to deny financial services to sanctioned parties and restricted persons.
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 explicit OFAC sanctions language and account freezing provisions eliminates specific transparency about how sanctions compliance may affect user accounts, replacing it with generalized regulatory compliance language.
View full change record →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.
How other platforms handle this
Medium may terminate or suspend your right to use our Services at any time for any or no reason upon notice to you.
Substack is free to terminate (or suspend access to) your use of Substack, or your account, for any reason at our discretion. We will try to provide advance notice to you prior to our terminating your account so that you are able to retrieve any important Posts you may have uploaded to your account,...
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 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.— Excerpt from Coinbase's Coinbase User Agreement
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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The provision establishes the operational requirement for Coinbase to enforce sanctions compliance as a condition of service provision. This reflects the company's legal obligation under U.S. law to deny financial services to sanctioned parties and restricted persons.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coinbase.