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Transparency Report 2022

By Paul Grewal

Company

, December 12, 2022

, 7 min read time

Coinbase

Coinbase is proud to publish our fourth Transparency Report. This report covers the period from October 1, 2021 through September 30, 2022. Last year’s report can be found here

Our goal with these reports is to provide customers with data about requests for their information that we receive from government agencies and law enforcement. We also intend to provide some insight into law enforcement and regulatory trends around the world.

At Coinbase, our mission is to promote economic freedom, and we believe the best way to do that is by increasing crypto adoption in the world. In pursuit of this mission, we have continued to expand into new international markets, adapting our products and services to these new geographies.  As crypto adoption continues to grow, we have seen a corresponding increase in the number of law enforcement and agency requests.  We seek to narrow requests that are overly broad or vague to provide a more appropriately tailored response, and in some cases we object to producing any information at all.  We also aim to provide anonymized or aggregated data instead of providing individual customer information.  Since last year’s report, these requests have more than doubled, which we attribute to a combination of our own expansion and an overall increase in law enforcement and regulatory interest in the crypto industry.  I encourage you to read this report to learn more about the types and volume of requests that Coinbase receives from agencies around the globe and how we respond to them.  

Transparency Report

Overview: Coinbase currently serves more than 108 million customers worldwide. We regularly receive and respond to requests from law enforcement and government agencies seeking customer account information and financial records in connection with civil, criminal, or other investigative matters. These requests can include subpoenas, court orders, search warrants, or other formal legal process. We have an obligation to respond to such requests if they are valid under financial regulations and other applicable laws.

This report shares data on the requests for information that Coinbase receives from government and law enforcement agencies around the world and provides a view into how government policies and actions intersect with customer privacy.

At Coinbase, trust is our greatest asset. We are committed to protecting our customers, by safeguarding both the assets they entrust to us and their financial privacy. We are also committed to aiding the critical role of law enforcement and government agencies in pursuing bad actors who engage in prohibited activity or seek to abuse our platform. In every instance, we carefully review law enforcement and agency requests before providing data to ensure we are honoring our customers’ rights over their personal information.

Each request we receive is carefully reviewed by a team of trained experts using established procedures to determine its legal sufficiency. Where necessary, we will seek to narrow requests that are overly broad or vague to provide a more appropriately tailored response, and in some cases we object to producing any information at all (such as if the request is legally insufficient). We also aim to provide anonymized or aggregated data that aids law enforcement and government agencies with their work, where it is possible to do so, instead of providing individual customer information. 

The charts below provide data on the number of requests we received this past year.

Key Takeaways:

  • There were a total of 12,320 requests during the reporting period, a ~66% increase over last year’s report.

Screenshot 2022-12-12 at 12.43.11 AM
  • The ~57% of requests from outside of the United States was a ~6% increase over our previous report. In addition, 21 Countries sent requests for the first time in 2022, including 11 that sent more than one: Andorra (2), Argentina (2), Brazil (5), Bulgaria (3), China (12), Croatia (3), Czech Republic (104), Liechtenstein (4), Serbia (5), Slovakia (6), Taiwan (6).

  • ~80% of law enforcement requests were from the U.S., U.K., Germany, and Spain.

Screenshot 2022-12-12 at 12.47.18 AM
  • Six countries increased their number of law enforcement and agency requests by over 100%: Spain (+940%), Belgium (+400%), Italy (+281%), Netherlands (+163%), Austria (+141%), and Ireland (+118%).

Screenshot 2022-12-12 at 12.48.12 AM
  • As in years past, the overwhelming majority of requests we received both globally and in the U.S. were from law enforcement agencies in connection with criminal enforcement matters.

Screenshot 2022-12-12 at 12.48.56 AM
Screenshot 2022-12-12 at 12.49.02 AM

FAQs:

Does this report include data about requests received by all Coinbase entities/services?

This report includes data about requests related to our various products and services including coinbase.com, coinbase.com/exchange, coinbase.com/prime, and custody.coinbase.com.

What does it mean if my country is not listed on the report?

We only include countries where (i) our services are available, and/or (ii) Coinbase received a government or law enforcement request. 

What is a government information request?

A variety of laws allow the government and law enforcement agencies of a given country to request the disclosure of customer information for civil, administrative, criminal, and national security purposes, including as part of an investigation.

What information does Coinbase provide in response to government and law enforcement requests?

Depending on the nature and scope of the request, Coinbase may produce certain customer information, such as name, recent login/logout IP address, and payment information; this type of information may be subject to requests by government and law enforcement agencies when a customer uses one of our applications or our website, as described in our privacy policy. Does Coinbase challenge or reject government requests?

Coinbase may challenge government and law enforcement requests, depending on the particular circumstances of each request. Under certain circumstances, we may ask the government or law enforcement agency to narrow their request.

Who reviews government requests for user information at Coinbase?

Coinbase has a trained team of lawyers, analysts, and other experts who review and evaluate each government and law enforcement request individually to assess its legal sufficiency and determine an appropriate response.

Does Coinbase provide governments with direct access to customer information?

Coinbase does not give any government in any jurisdiction (including law enforcement, or other government agencies) direct access to customer information on our or any third-party’s systems.

*1 Last year’s Transparency Report included data for the first three quarters of 2021. Our intention going forward is to produce a report in December of each year that includes a year of data running from Q4 the previous year through Q3 of the current year.

*2  The absolute numbers in this year’s report are slightly more than double last year’s report, but this year’s report covers a complete year instead of the nine months covered last year. As we adopt a full year reporting cycle going forward, numbers should be more easily compared from year to year.

* 3 Coinbase receives various criminal, civil and administrative requests from regulators and agencies in various countries seeking information about specific accounts and transactions.  This Transparency Report reflects data related to these requests; it does not include customer initiated requests for information or productions required as part of routine regulatory examinations or in connection with civil litigation between private parties.

* 4 To Normalize the data between this year and last year, we compared last year's total to 75% of this year's total to calculate the increase.

*5  These numbers are also adjusted to make this year directly comparable to last year.

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Paul Grewal

About Paul Grewal

Paul Grewal is the Chief Legal Officer of Coinbase where he is responsible for Coinbase’s legal, compliance, global intelligence, risk management and government relations groups. Before joining Coinbase, Paul was Vice President and Deputy General Counsel at Facebook. Prior to Facebook, Paul served as United States Magistrate Judge for the Northern District of California. Paul was previously a partner at Howrey LLP, where his practice focused on intellectual property litigation. Paul served as a law clerk to Federal Circuit Judge Arthur J. Gajarsa and United States District Judge Sam H. Bell. He received his JD from the University of Chicago Law School and his BS in Civil and Environmental Engineering from the Massachusetts Institute of Technology.