Business must screen transactions for sanctions compliance

The updated terms expand Coinbase's authority to liquidate your assets without notice. Previously, Coinbase could liquidate your property only if you failed to pay for securities you purchased or failed to deliver securities you sold through CCM. The revised language adds a new trigger: if a transfer of securities into your CCM account fails or is reversed, Coinbase can now liquidate your property to cover any losses CCM suffers as a result. This means your assets may be liquidated for reasons beyond your direct control, such as a failed inbound transfer initiated by a third party or a reversal by the sending institution.

The updated terms authorize Coinbase to automatically transfer your digital assets to a newer protocol version when an 'Asset Transformation' occurs, and you are now instructing Coinbase to conduct these 'Coinbase Supported Migrations' at Coinbase's sole discretion. The terms also establish that Coinbase shall not be liable for any loss resulting from your inability to transfer assets during a migration or from an Asset Transformation itself. This means Coinbase can execute asset transfers without advance notice and without bearing responsibility for any resulting losses, even if the transfer fails or the new asset version performs differently than the original.

The updated terms introduce a new Direct Deposit feature that allows eligible users to receive paychecks and government benefits directly into their Coinbase Account and optionally convert those funds into digital assets through recurring automatic purchases. The terms state that Coinbase will not charge setup or maintenance fees and will waive trading fees on Direct Deposit conversions, though spreads may apply. However, the terms also establish that digital assets are not FDIC-insured, can appreciate or depreciate relative to USD, and that Coinbase reserves the right to set, modify, or reject transfer limits at its sole discretion. You can enroll by providing your employer or government payer with the virtual account and routing numbers Coinbase provides, and you can change your asset allocation at any time through the Coinbase app.