Provision record
MetaMask · MetaMask Terms of Use · View original document ↗

mUSD Compliance Controls and Freeze Risk Disclaimer

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Document Record

What it is

The Agreement discloses that third-party compliance, sanctions-screening, and security providers associated with mUSD may restrict, freeze, block, or seize user access to mUSD at their discretion or pursuant to legal requirements, and that Consensys bears no liability for such actions or their consequences.

This analysis describes what MetaMask'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 discloses that mUSD assets held or transacted through MetaMask are subject to unilateral restriction, freeze, or seizure by third-party compliance and security providers without prior notice, and that Consensys is not responsible for reviewing, challenging, or remediating such actions.

Recent Activity

This document changed recently

Medium Jul 1, 2026

The updated terms explicitly state that UK, EU, and EEA consumers retain statutory consumer protection rights that cannot be limited or excluded by the agreement, and that applicable local law prevails in the event of conflict with these terms. This adds clarity to the legal framework but does not change substantive protections for those users. The terms also clarify that mUSD is a third-party digital asset not issued by Consensys, treating it as a third-party service subject to the agreement's limitations on Consensys' responsibility for third-party services.

View change record →

Clause Stability Stable

0
Changes
5
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users who acquire or hold mUSD through MetaMask accept that third parties may freeze, block, or otherwise impair their access to those assets without prior notice, and that Consensys will not intervene or bear liability for any resulting loss of access, value, or liquidity. The Agreement states that addresses associated with actual or suspected suspicious activity may be subject to restriction or freeze.

Cross-platform context

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▸ View Original Clause Language DOCUMENT RECORD
"
YOU UNDERSTAND AND ACCEPT THAT ANY SUCH THIRD PARTY MAY RESTRICT, REJECT, DELAY, BLOCK, BLACKLIST, FREEZE, QUARANTINE, DISABLE, SEIZE, BURN, OR OTHERWISE IMPAIR YOUR ABILITY TO ACCESS, HOLD, TRANSFER, RECEIVE, REDEEM, SWAP, BRIDGE, SPEND, OR OTHERWISE USE mUSD. YOU AGREE THAT YOU ALONE, AND NOT CONSENSYS, ARE RESPONSIBLE FOR YOUR DECISION TO ACQUIRE, HOLD, OR USE mUSD OR TO ENGAGE IN ANY TRANSACTION INVOLVING MUSD.

Excerpt from MetaMask's Terms of Use

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: The mUSD compliance and freeze provisions engage OFAC sanctions compliance requirements, FinCEN anti-money laundering obligations, EU AML directives, and evolving digital asset regulatory frameworks including MiCA (EU Markets in Crypto-Assets Regulation) for …

Insight

Unlock the full institutional analysis

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 →
  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
MetaMask Terms of Use
Entity
MetaMask
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-015124
Document ID
CA-D-00279
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
fbc3e940d542d736f423bed59d696fff5bef4265893e8cc2ffd8581c3ba58f1d
Analysis generated
July 9, 2026 07:13 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: MetaMask
Document: MetaMask Terms of Use
Record ID: CA-P-015124
Captured: 2026-07-09 07:13:37 UTC
SHA-256: fbc3e940d542d736…
URL: https://conductatlas.com/platform/metamask/metamask-terms-of-use/provision/CA-P-015124/musd-compliance-controls-and-freeze-risk-disclaimer/
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 MetaMask's mUSD Compliance Controls and Freeze Risk Disclaimer clause do?

This provision discloses that mUSD assets held or transacted through MetaMask are subject to unilateral restriction, freeze, or seizure by third-party compliance and security providers without prior notice, and that Consensys is not responsible for reviewing, challenging, or remediating such actions.

How does this clause affect you?

Under this clause, users who acquire or hold mUSD through MetaMask accept that third parties may freeze, block, or otherwise impair their access to those assets without prior notice, and that Consensys will not intervene or bear liability for any resulting loss of access, value, or liquidity. The Agreement states that addresses associated with actual or suspected suspicious activity may …

Is ConductAtlas affiliated with MetaMask?

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