Provision record
Coinbase · Coinbase User Agreement · View original document ↗

Sole Discretion Account Suspension and Termination Without Disclosure

High severity Unique · 0 of 352 platforms
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Document Record

What it is

Coinbase may immediately suspend, restrict, or terminate any user account for any reason at its sole discretion, without being required to disclose the reason or the risk criteria that informed the decision. Users retain a 90-day window to transfer assets after account deactivation unless prohibited by law or court order.

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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes immediate account suspension or termination without prior notice or disclosed justification, based on confidential risk criteria. The operational consequence for users is that access to digital assets and USD wallet funds may be interrupted without advance warning, subject to the 90-day transfer window and any applicable legal restrictions.

Recent Activity

This document changed recently

Medium Sep 3, 2026

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 →
High Jul 23, 2026

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 →
Medium Jul 7, 2026

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 →

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Close Your Account
    Visit https://accounts.coinbase.com/profile/close to close your account. Ensure all outstanding balances owed to Coinbase are paid before closure. Pending transactions will be cancelled upon closure.

If You Do Nothing

If an account is deactivated and assets are not transferred within 90 days, further transfer may be restricted by applicable law or court order as stated in the agreement

Cross-platform context

See how other platforms handle Sole Discretion Account Suspension and Termination Without Disclosure and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
Coinbase may suspend, restrict, or terminate your access to any or all of the Coinbase Services, and/or deactivate or cancel your Coinbase Account(s), with immediate effect for any reason at its sole discretion and is under no obligation to disclose the details of its decision to take such action with you. You acknowledge that Coinbase's decision to take certain actions, including limiting access to, suspending, or closing your account for any reason in our sole discretion, may be based on confidential criteria that are essential to Coinbase's risk management and security protocols. You agree that Coinbase is under no obligation to disclose the details of its risk management and security procedures to you.

Excerpt from Coinbase's User Agreement

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Consumer Financial Protection Bureau (cfpb)
    Regulates consumer financial products and services. Can investigate companies for unfair, deceptive, or abusive financial practices including improper fees, billing errors, and data misuse.
    Who can file: Anyone who has used a consumer financial product or service in the US
    What you need: Account number or details, dates of transactions or events, description of the issue, and any supporting documents
    What to expect: The company must respond within 15 days. The CFPB forwards your complaint and may use it in enforcement actions. Individual compensation is possible in some cases.
    File a complaint →
  • State Attorney General
    State AGs in California, New York, Texas, and other states can investigate violations of state consumer protection and privacy laws, including CCPA (California), SHIELD Act (New York), and equivalents.
    Who can file: Residents of states with comprehensive privacy laws — primarily California, Virginia, Colorado, Connecticut, and Utah
    What you need: Evidence of the violation, explanation of how your state rights were affected, and your account or contact information with the company
    What to expect: Outcomes vary by state. May result in investigation, enforcement action, or requirement for the company to change practices. No direct individual compensation in most cases.

    Search "[your state] attorney general consumer complaint" to find your state's direct complaint form

Applicable regulations

EFTA / Reg E
United States Federal

Provision details

Document information
Document
Coinbase User Agreement
Entity
Coinbase
Document last updated
May 5, 2026
Tracking information
First tracked
July 12, 2026
Last verified
July 12, 2026
Record ID
CA-P-00047001
Document ID
CA-D-00047
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
a9f500133b028586c3ef699c5845c93a81e3d2523e0ad6b93c23e63feb318580
Analysis generated
July 12, 2026 02:00 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Coinbase
Document: Coinbase User Agreement
Record ID: CA-P-00047001
Captured: 2026-07-12 02:00:01 UTC
SHA-256: a9f500133b028586…
URL: https://conductatlas.com/platform/coinbase/coinbase-user-agreement/sole-discretion-account-suspension-and-termination-without-disclosure/
Accessed: Sept. 8, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Coinbase's Sole Discretion Account Suspension and Termination Without Disclosure clause do?

This provision authorizes immediate account suspension or termination without prior notice or disclosed justification, based on confidential risk criteria. The operational consequence for users is that access to digital assets and USD wallet funds may be interrupted without advance warning, subject to the 90-day transfer window and any applicable legal restrictions.

Is ConductAtlas affiliated with Coinbase?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Coinbase.