Coinbase’s Philosophy on Account Removal and Content Moderation

By Brian Armstrong

In the previous few years, it’s turn out to be more and more frequent for tech firms to censor prospects or shut their accounts for a variety of causes (e.g., misinformation). Luckily, as a crypto enterprise we don’t face this problem as steadily as a social community does, however we nonetheless must set clear insurance policies round acceptable use of our merchandise. As our product suite grows, it is going to even embrace merchandise that host consumer generated content material like NFTs.

Our excessive stage philosophy is that, in a democratic society, the individuals and their elected officers ought to resolve what habits is allowed and never allowed by setting legal guidelines. We suppose it units a harmful precedent when tech firms, akin to Coinbase, or their executives begin making judgment calls on tough societal points, appearing as decide and jury. This method sounds easy in principle, however in observe it’s something however.

First, it may be very complicated to find out whether or not an exercise is authorized or unlawful. Laws fluctuate vastly throughout completely different international locations, states, and areas. Some actions are authorized solely you probably have a license. Some exercise is in a grey space. Some unjust legal guidelines go unenforced. Like most firms, we refer suspected criminality to the related authorities, however we are able to’t anticipate to obtain a well timed response or opinion again from them given the numerous calls for on their assets. Unfortunately, this places us, together with most firms, within the unlucky place of getting to make our personal determinations about what exercise is authorized or unlawful.

Second, even when some exercise is authorized, it could be one thing that’s deeply troubling to have on the platform. The world is plagued by polarizing, uncomfortable, or obscene content material which will nonetheless be authorized. This is the place firms begin to train much more judgment on what they permit. But there may be nice hazard of falling down a slippery slope, having to render choices on each tough societal problem, the place you’re certain to upset somebody regardless of the place you land. Without some robust principled based mostly method, these choices turn out to be arbitrary and capricious, opening the corporate to assault.

Finally, each firm works with different firms which have their very own set of moderation and deplatforming insurance policies. For occasion, for any app to be listed within the Apple and Google App Stores, it must play by the principles of these two firms. In the monetary providers world, we additionally work with banks and cost processors who’ve their very own acceptable use insurance policies. Very few firms are utterly vertically built-in, with the luxurious of constructing their very own choices in a vacuum.

So how ought to an organization implement an inexpensive method based mostly on the above constraints? We’ve provide you with our personal reply, and I need to share it right here so our prospects can perceive it, and in case it helps different firms.

Our method

First, it’s vital to distinguish our method based mostly on the kind of product. Coinbase has a broad product suite, however for moderation functions we group our merchandise as both infrastructure merchandise or public-facing merchandise when fascinated by learn how to reasonable them. Infrastructure merchandise allow entry to primary monetary providers and are sometimes used privately by a single buyer, whereas public-facing merchandise typically host consumer generated content material and have social options seen to massive numbers of customers. Ben Thompson’s article on moderation in infrastructure illustrates how firms sometimes take a special method for every of those merchandise.

For our infrastructure merchandise, we use rule of legislation as the muse of our method, as a result of we imagine that governments, not firms, must be deciding what’s allowed in society. We additionally imagine that everybody deserves entry to monetary providers, and a check of legality must be adequate for these merchandise.

For our public-facing merchandise, we once more begin with rule of legislation as the muse. But assuming one thing is authorized in a sure jurisdiction, we additionally transcend this and reasonable content material that’s not protected speech beneath the First Amendment. We’re not legally held to the First Amendment as an organization, and the First Amendment is a U.S. centered idea solely, however we’ve chosen to make use of it because the tenet of our content material moderation method as a result of it’s in step with our values and helps guarantee we don’t fall down a slippery slope over time. The First Amendment has a whole lot of years of case legislation constructed up, and supplies an inexpensive framework to reasonable content material akin to incitement, preventing phrases, libel, fraud, defamation and many others. David Sacks does an ideal job describing this method in this blog post.

Finally, there are circumstances the place we need to work with exterior companions, such because the App Stores, and must comply with their moderation insurance policies to take action. Sometimes third celebration cost suppliers have their very own insurance policies. For cost suppliers, we are able to merely disable performance associated to that accomplice if there’s a downside with a selected consumer, whereas persevering with to supply Coinbase providers. But getting kicked out of the app shops wouldn’t assist anybody. So when working with companions, our method is to be free speech supporters, however not free speech martyrs, and to make lodging whether it is important for us to perform as a enterprise.

This is clearly a fancy problem, and hopefully the above method begins to point out a path via it that doesn’t devolve into arbitrary and capricious resolution making. To boil down the above method, we ask the next questions for our public-facing merchandise:

1. Is the content material unlawful in a jurisdiction through which we function?

A. If sure, then take away in that particular jurisdiction

2. Is the content material a free speech exception beneath the First Amendment?

A. If sure, then take away globally

3. Has a important accomplice required us to take away the content material?

A. If sure, then take away the content material or disable the performance of that accomplice for the affected consumer

If the reply to any of those 3 questions is “Yes” we are going to take some moderation motion, akin to taking down content material and in extreme circumstances terminating the account.

Decentralization is the last word buyer safety

Most of this submit has been about how we are able to create an inexpensive moderation coverage that doesn’t get co-opted over time, succumb to stress, or descend into us taking part in decide and jury. This is vital in order that Coinbase is ready to stand as much as stress. Of course, the decentralized nature of cryptocurrency gives its personal vital protections right here, and people protections get stronger the extra our merchandise decentralize.

If our coverage above fails, and Coinbase begins making unhealthy judgment calls or turns evil, prospects can withdraw their crypto to some other competing alternate, pockets, or custodian. Compare this to social networks at the moment, the place you’ll be able to’t take your followers with you. Your knowledge is owned by one firm, in a proprietary format. The open nature of crypto protocols supplies decrease switching prices, which is a vital buyer safety, even for comparatively centralized crypto merchandise. But decentralized, or self-custodial, crypto merchandise have a good better safety as a result of the corporate is just offering entry to one thing operating on-chain. For occasion, nobody can deplatform your ENS title with out taking each ENS title offline. Decentralization strikes you from the slippery slope to the crypto cliff, the place the would-be censor should compromise a complete blockchain to censor only one particular person.

Decentralization is a spectrum, and Coinbase is shifting farther down this path over time, embracing self-custody with Coinbase Wallet, stepping up consumer schooling round non-public keys, and by investing in Bitcoin core growth and web3 protocols. The extra decentralization we are able to help, the higher safety prospects will have.


We imagine everybody deserves entry to monetary providers, and that firms ought to put acceptable controls in place to stop censorship or unjust account closures from going down. For centralized monetary infrastructure merchandise, we imagine rule of legislation is a adequate normal for moderation, whereas for decentralized merchandise even better protections will be offered by the blockchain. We additionally acknowledge that public-facing merchandise deserve some extra consideration, and that the First Amendment can be utilized as an inexpensive check or boundary. We imagine this method is in keeping with our mission of making extra financial freedom on this planet and with the ethos of crypto.

Companies are in a tough place after they select to censor or terminate a buyer account. What typically looks like a simple resolution, particularly beneath public stress, seems to have bigger unintended penalties and units a harmful precedent for the position of personal firms in society. I’m certain we gained’t get it excellent with our coverage above, however my hope is that we’ve laid out some ideas we are able to fall again on when tough choices come up, and that buyers, prospects, and workers can have a greater understanding of our course of.

Further Reading

Coinbase’s Philosophy on Account Removal and Content Moderation was initially revealed in The Coinbase Blog on Medium, the place individuals are persevering with the dialog by highlighting and responding to this story.

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