Uphold review: licences, terms and gambling clause
Can you deposit to a casino from Uphold?
Uphold's terms restrict gambling without banning it outright, in Prohibited Businesses and Prohibited Use, Prohibited Use list (last updated Jan 5, 2024); a deposit to a casino not licensed where you live can breach them. Its terms let it freeze or suspend an account. No registration is confirmed in an issuing register. KYC rules: no data in this entry.
Documents last checked Reviewed by CryptoGuardz Register Desk, editorial desk
Disclosure: CryptoGuardz has no commercial relationship with Uphold, earns nothing if you open an account there, and has not contacted the company or given it notice of this entry. Every statement below is either a verbatim quote from a document Uphold publishes or a statement about a public register, and both carry the date they were read. Corrections go to the corrections page.
1. What this means for you
Consequences first, in the conditional, each one produced by a clause in a document Uphold publishes itself. Every line links to that clause, quoted in full and dated.
- Your account can be suspended or closed for any reason Uphold gives The freeze clause itself requires notice, but a separate ground lets the exchange suspend or terminate an account for any reason. Both are quoted below.
- Your withdrawal can be suspended if Uphold decides an incident on the platform requires it The withdrawal clause sets no maximum duration and no external test for when an incident is resolved.
- Your coins can be pooled with everyone else's if Uphold holds them the way its terms describe The terms state that client assets may not be segregated from the exchange's own assets.
- You have no authority to complain to if something goes wrong, because no registration could be confirmed No authorisation claimed by Uphold was found in an issuing authority's own public register.
- You cannot see who checked the proof of reserves, because the public page does not name them The page says an independent accountant performs the review but names no firm and no standard. A signer nobody can identify is not counted as an independent signer.
- You may breach the terms if the casino you fund is unlicensed where you live Uphold's clause covers unlawful, unregulated or illegal gambling rather than gambling as such. It is quoted in section 10.
2. What this entry records, and what it does not
This register publishes no number for an exchange. The payout score on the casino register has five defined components and a published arithmetic; no equivalent instrument exists here, and inventing one to fill the space would be a measurement nobody made. What follows instead is a field-by-field account of what was read, where it was read and when.
| Binding terms | Read in full 8 clauses captured verbatim across 7 topics, retrieved 2026-10-08 |
|---|---|
| Contracting entity | Uphold HQ Inc.No jurisdiction of incorporation stated in the binding document · no company number stated |
| Registration check | Nothing confirmed in any issuing registerESMA interim MiCA register, published CSV, read 2026-10-08 |
| Proof of reserves | Published, signer not namedNo signer named on the public page. |
| Insolvency outcome | Stated in the terms Quoted in section 7 |
| Withdrawal test | Not measuredNo first-party deposit or withdrawal has been run against this exchange. It would require funding an account, which this register has not done. Until it has, nothing here is a measurement of how fast the exchange pays. |
| On-chain reserve verification | Not measuredNo independent reconstruction of the Merkle tree or of the exchange's wallet holdings has been attempted. |
3. What we could not verify
Every entry carries this section. The gaps are published because a reader deserves the limits of the check as well as its results.
- The state of organisation and company number of Uphold HQ Inc. Neither appears in the US agreement.
- State money transmitter licences. The agreement claims them without numbers and no state register was read.
- The FinCEN MSB registration. msb.fincen.gov is disallowed by robots.txt to the retrieval tool.
- Any EU or UK authorisation. The EEA and UK agreements were not read. The ESMA CASP register file was served truncated at 81,166 characters (ending at the DEBLOCK SAS row) on two attempts, so absence from it cannot be asserted. The FCA register returned a JavaScript error page on two attempts.
- Uphold's reserve figures. The transparency page shows them only after login.
- The USDT withdrawal networks. Uphold's support article on crypto network withdrawals and its USDT page do not list them; the article points to a networks table that was not located.
4. Who you are contracting with
The counterparty named in the binding document, not the brand on the website. This is the company a claim would be brought against and whose insolvency estate a user would be a creditor of.
| Named counterparty | Uphold HQ Inc.source · retrieved 2026-10-08 |
|---|---|
| Jurisdiction of incorporation | Not disclosedNo place of incorporation is stated in the binding document read. What the document does say is in the notes below. |
| Company number | Not disclosedNo company number appears in the binding document, so the entity cannot be looked up in any companies register from that document alone. |
The document read is the User Agreement for Residents and Businesses of the United States and Canada, last updated Aug 20, 2026. It names Uphold HQ Inc. ("Uphold US") as the counterparty for US users, with an address at 228 Park Ave. S., #50458, New York, NY 10003-1502, and Uphold Operating Canada Ltd. ("Uphold Canada"), described as "an entity based in British Columbia, Canada", for Canadian users. Neither a state of organisation nor a company number is given for Uphold HQ Inc., so both fields are recorded as not disclosed.
Users outside the US, Europe and the UK contract with a Bahamas company. The User Agreement for Residents of Countries Outside of the US, Europe, and UK, last updated Aug 20, 2026, opens: "It is a binding contract between you and Uphold Worldwide Ltd. (“Uphold”), Reg No. 177867, Registered Office: Aristo House, Office A, The Balmoral, #78 Sanford Drive, Nassau, Bahamas." It names no licence or regulator for Uphold Worldwide Ltd.
The EEA and UK agreements were not read for this entry. Every clause below binds a US user only.
If you are a US User, you agree that the laws of the State of California, without regard to principles of conflict of laws, govern this Agreement and any claim or dispute between you and Uphold US, except to the extent governed by U.S. federal law or otherwise required by applicable law.uphold.com
5. Registrations, claimed and confirmed
No registration Uphold claims could be found in an issuing authority's own public register. That is an absence of confirmation, not evidence that a registration is invalid. No licence held by any Uphold entity was confirmed in a regulator's register for this entry. The Bahamas company that contracts with users outside the US, Europe and UK names no licence at all in its own agreement.
| Authority | Kind | Confirmed | What it covers |
|---|---|---|---|
| New York State Department of Financial Services (NYDFS), virtual currency licence | authorisation | no | Not applicable. Uphold does not claim a NYDFS licence in the agreement read. This row records a negative check: the NYDFS list of regulated virtual currency entities, 39 rows, was read on 8 October 2026 and no Uphold entity appears in it. |
| US state money transmitter licences (various states) | authorisation | no | The US agreement refers to state money transmitter licences held by Uphold US and gives no licence numbers. Its California appendix states: "Uphold US has applied to the California Department of Financial Protection and Innovation (“DFPI”) for a license under the California Digital Financial Assets Law (Fin. Code § 3101 et seq.) (“DFAL”)." That is an application, not a licence. Not confirmed: no state register was read. |
| Financial Crimes Enforcement Network (FinCEN), money services business registration | authorisation | no | A FinCEN MSB registration is an anti-money-laundering registration, not a licence to operate an exchange. Not confirmed: msb.fincen.gov is disallowed to this register's retrieval tool by the site's robots.txt, so the MSB registrant search was not run. |
| European Securities and Markets Authority (MiCA register of non-compliant entities) | adverse listing | not listed | Negative check. The official ESMA register of non-compliant entities providing crypto-asset services was retrieved on 8 October 2026 (173 data rows, ending with a complete row) and searched. The string Uphold does not appear in it. |
6. Proof of reserves
Uphold publishes a proof of reserves and says an outside party performs it, but the public page names nobody, so it is not counted as independently signed. It says nothing about what the exchange owes.
| Signer | No dataNo signer is named on the public page. |
|---|---|
| Standard | None named on the public page. |
| As of | No dataNo as-of date could be read from the page at retrieval. |
| Covers liabilities | noNothing in the exercise addresses borrowings, loan obligations, off-chain claims, or whether the set of user balances in the tree is complete. |
| Page | uphold.comretrieved 2026-10-08 |
Uphold's transparency page says it publishes assets and liabilities in real time, but the public page shows no figures: it reads "Login to see Uphold’s Reserve by Tier". No as-of date, no attestation firm and no standard are named. The page mentions "regular US State audits" without naming an auditor. SOC 2 Type 2, ISO 27001 and PCI DSS are listed, none of which is a reserve attestation.
The page claims "The Uphold platform is always 100%+ reserved" and "Your money is 100% reserved", qualified by "unless you have explicitly chosen to stake or use DeFi lending". These are recorded as Uphold's own claims, not as facts. Because the reserve figures are login-only, this register could not read them.
7. Custody, segregation and insolvency
What the binding document says about where your coins sit and what happens to them if the exchange fails, quoted rather than characterised.
Although Uphold will retain internal ledgers indicating the amount and type of Funds held by each User, Funds will not be segregated by User and will be commingled with Funds of other Users.uphold.com
In the event of the insolvency of Uphold US, or its custodial partners, you understand that your rights to cryptoassets may, depending on the user's jurisdiction and applicable law, be treated as those of a general unsecured creditor under applicable bankruptcy law.uphold.com
Digital financial assets that Uphold US controls on your behalf are held for your benefit, are not the property of Uphold US, and are not subject to the claims of Uphold US’s creditors.uphold.com
8. Freezing your account
1 clauses, quoted in the order they appear in the document. Read the last one first: it is the ground that swallows the others.
In some cases we may terminate, suspend or otherwise restrict your Account and use of the Platform if we suspect your Account(s) may be connected to any Prohibited Use or Prohibited Business, for suspected violation of this Agreement or any applicable agreements or policies, where required by applicable law, or to otherwise prevent potential loss.uphold.com
9. Suspending withdrawals
Uphold US may delay, suspend, or reverse transactions where required for fraud prevention, sanctions screening, BSA/AML review, or where required by law or by our banking or payment partners.uphold.com
10. Sending funds to a casino from Uphold
Uphold's terms restrict gambling only where it is unlawful, unregulated or illegal. Whether a deposit to a given casino breaches them depends on that casino's licence and on where you are.
Partake in any transaction involving online gambling except where permitted and with our prior written permissionuphold.com
In some cases we may terminate, suspend or otherwise restrict your Account and use of the Platform if we suspect your Account(s) may be connected to any Prohibited Use or Prohibited Business, for suspected violation of this Agreement or any applicable agreements or policies, where required by applicable law, or to otherwise prevent potential loss.uphold.com
The Prohibited Use list is introduced by: "You may not use your Account or the Uphold Platform to engage in the following categories of activity (“Prohibited Use”)." The Prohibited Businesses list on the same page also includes "Gambling, except where permitted by and with our prior written permission" and "Casinos, lotteries and gambling (online or in-person)". The US User Agreement itself contains none of the words gambling, gaming, lottery, casino, betting, wager or sweepstakes; it refers to Prohibited Use and Prohibited Business and lets Uphold restrict an account suspected of being connected to either.
11. Which networks Uphold withdraws USDT on
No dataThe network list could not be confirmed. See the note below.
Uphold's support article on crypto network withdrawals (last updated September 01, 2026) does not list networks per asset and refers to a networks table and to the transparency page. Neither the article nor uphold.com/en-us/prices/stablecoins/usdt-tether names the networks Uphold supports for USDT, so no chain is counted. Source. Which DEXes operate on each of those chains is in the DEX register.
12. Amendment, liquidation, arbitration and governing law
The clauses that decide what the contract can become, what can be done to an open position, and where a dispute would be heard.
We may amend or modify this Agreement by posting on the Platform or emailing to you the revised Agreement.uphold.com
This section (the "US Arbitration Provision") sets forth the circumstances and procedures under which claims (as defined below) from US Users shall be arbitrated instead of litigated in court upon the election of either party.uphold.com
13. Public record
Matters of public record, taken from primary sources and stated with them. They are not scored, because a historical event is not a measurement of how the exchange behaves today, and leaving them out while citing the sources would be worse.
The US Treasury's Office of Foreign Assets Control announced: "OFAC Settles with Uphold HQ Inc. for $72,230.32 Related to Apparent Violations of Multiple Sanctions Programs". The enforcement release refers to 69 apparent violations of the Iranian Transactions and Sanctions Regulations and 25 apparent violations of the Cuban Assets Control Regulations, and also covers Venezuela-related transactions.
The New York Attorney General announced that she had "secured more than $5 million from the cryptocurrency platform Uphold HQ, Inc. (Uphold) for misleading investors and promoting a fraudulent cryptocurrency investment scheme orchestrated by Cred, LLC (Cred)". The release states that the investigation "found that Uphold misleadingly promoted and offered Cred’s investment product, CredEarn, to its customers, in violation of New York law" and that "Uphold will pay $5 million to harmed investors". The settlement is an Assurance of Discontinuance, No. 26-005.
14. Who should avoid Uphold
Anyone who needs an authority to complain to. No registration Uphold claims could be confirmed in an issuing register, so there is no supervisory body this register can point a user at when something goes wrong.
Related entries
Or read the whole exchange register, the same method applied to wallets and to crypto casinos, the clause library at clause watch, or how this register works.