The agreement requires users to comply with applicable laws and authorizes Coinbase to request additional identifying information and documents as part of AML and KYC compliance obligations before or during use of the platform.
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 establishes Coinbase's authority to request identity and compliance documentation from users and to condition service access on completion of verification requirements, consistent with Coinbase's obligations as a registered money services business.
The updated terms expand Coinbase's authority to liquidate customer assets without notice to cover clearinghouse losses. Previously, liquidation was authorized only if you failed to pay for securities purchased or failed to deliver securities sold. The revised language now also permits liquidation if a transfer of securities into your account at CCM fails or is reversed. This means the platform can use your property to cover losses stemming from incoming transfer failures, in addition to settlement failures on your own trades. The authorization continues to require only that CCM make a demand for payment to Coinbase, without notice to you.
View change record →The updated terms establish procedures for handling protocol upgrades and define Coinbase's role in migrating customer assets to new versions. Under the revised language, by maintaining a Coinbase account, customers are deemed to have instructed Coinbase to conduct Coinbase Supported Migrations on their behalf at times and in manner Coinbase solely determines appropriate. The agreement further states that Coinbase shall not be liable or responsible for any loss resulting from inability to transfer Digital Assets during a migration or from the Asset Transformation itself. This expands Coinbase's authority to act without advance notice while eliminating liability for migration-related losses.
View change record →The updated terms now explicitly disclose Coinbase's fee structure for California residents, establishing a $10 maximum fee for transactions under $200 and a 6% maximum for larger transactions, though actual fees displayed at checkout may be lower based on payment method, order size, market conditions, and location. The revised agreement also clarifies that virtual currency transactions may be irreversible and provides links to procedures for reporting unauthorized transactions, updating contact information, and accessing transaction receipts. Coinbase commits to providing California residents at least 14 days' prior notice of material changes to fees or terms affecting their accounts.
View change record →Expanded from limited KYC/AML disclosure to broader ongoing data collection at any time Coinbase deems necessary, including wireless carrier authorization and unspecified personal data.
View full change record →This new standalone provision elevates KYC/AML requirements and gives Coinbase explicit authorization to demand additional verification documents before service provision.
View full change record →Users are required to provide identity verification information and additional documentation as requested by Coinbase under AML and KYC requirements. Failure to provide required documentation may affect access to platform services.
How other platforms handle this
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You agree that Promotional Codes: (a) must be used in a lawful manner; (b) must be used for the intended audience and purpose; (c) may not be duplicated, sold or transferred in any manner...
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"Before you use our Services, you represent and warrant that you will comply with all applicable laws and regulations. We may require you to provide additional information and documents as part of our verification process, in accordance with our obligations under applicable anti-money laundering (AML) and know-your-customer (KYC) regulations.Excerpt from Coinbase's User Agreement
1) REGULATORY LANDSCAPE: This provision directly engages FinCEN's AML program requirements for money services businesses under the Bank Secrecy Act, OFAC sanctions compliance obligations, and applicable state money transmission licensing requirements that impose customer identification …
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This provision establishes Coinbase's authority to request identity and compliance documentation from users and to condition service access on completion of verification requirements, consistent with Coinbase's obligations as a registered money services business.
Users are required to provide identity verification information and additional documentation as requested by Coinbase under AML and KYC requirements. Failure to provide required documentation may affect access to platform services.
ConductAtlas has identified this type of provision across 282 platforms. See the full comparison.
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