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 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 →How other platforms handle this
you represent and warrant that (1) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a "terrorist supporting" country
You are not listed on any U.S. Government list of prohibited or restricted parties.
You must comply with all domestic and international export laws and regulations that apply to the software and/or Services, which include restrictions on destinations, end users, and end use.
"You represent and warrant that you are not, and have not been, designated by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) as a "Specially Designated National" or blocked person.Excerpt from Coinbase's User Agreement
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The clause states: “You represent and warrant that you are not, and have not been, designated by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) as a "Specially Designated National" or blocked person.”
ConductAtlas has identified this type of provision across 182 platforms. See the full comparison.
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