Cryptoassets Regulatory Intelligence cryptoassets.gi
US-ME v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 0 failing12 sources retrieved model claude-sonnet-5 · 2026-08-06

Maine, USA

US-ME schema crypto-v2.0.0 trajectory: not yet assessedregulatedoverlaps: FIM, WPM

Last updated · 8 categories · 21 sourced findings · 29 sources in the cumulative register

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United States federal law that applies in Maine, USA is covered once, on the United States page. This page covers Maine, USA’s own layer: its own law, regulators and enforcement.

Jurisdiction lead brief

Latest update · 18 October 2026

Lead Signal

Maine's virtual-currency consumer-protection posture tightened this cycle through the interaction of two standing instruments rather than through any single new enactment. The Virtual Currency Kiosk Act, codified at 32 M.R.S. c.80 subch.4, requires kiosk operators to provide clear and conspicuous disclosure of material risks, including the risk of fraud or loss and the exchange rates charged to the customer. That statutory disclosure duty sits alongside the January 2026 consent agreement between the Maine Bureau of Consumer Credit Protection and Bitcoin Depot, in which the operator agreed to pay 1.9 million dollars to compensate consumers defrauded by third-party scammers operating through its kiosks and committed to comply with money-transmitter-licensing and unhosted-wallet provisions going forward. Read together, the disclosure duty and the enforcement outcome show a consumer-protection regime that is sectoral and kiosk-focused rather than general, but is actively supervised where it does apply.

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#

Maine has no bespoke crypto-asset licensing statute. Virtual-currency exchange, custody, and transmission businesses fall under Maine's general money-transmitter licensing law, administered through the Nationwide Multistate Licensing System (NMLS), consistent with the seed disambiguation. The exact statutory chapter/section citation and any crypto-specific carve-outs have not been independently verified against Maine's primary statute in this research pass, so materiality-5 licensing claims carry Probable rather than Confirmed confidence pending primary-source escalation.

Standing sub-brief · as of 25 August 2026470 words · last cycle 2026-10-11

Crypto Licensing

Maine's baseline position is that any administrator or exchanger that accepts and transmits convertible virtual currency, or that buys or sells it for any reason, is a money transmitter under state law and must be licensed or registered accordingly. This principle, drawn directly from the Maine Bureau of Consumer Credit Protection's own consumer guidance, has functioned as the default crypto-licensing gateway in the absence of any Maine-specific crypto licensing category. This cycle brings two material enactments that tighten how that default gateway applies to a specific and previously under-regulated segment: cash-dispensing machines operated as virtual-currency kiosks.

Periodic update · new data 2026-10-11

Crypto Licensing

Maine's Virtual Currency Kiosk Act, codified at 32 M.R.S. section 6165, requires any virtual-currency-kiosk operator to be licensed as a money transmitter under the Money Transmission Modernization Act unless exempt under 32 M.R.S. sections 6074-6075; this requirement has been in force since June 12, 2025. The Bureau of Consumer Credit Protection's consent agreement with Bitcoin Depot Operating, LLC, effective January 5, 2026, is the clearest demonstration yet of this licensing requirement's enforcement teeth: BDO operated unlicensed kiosks from 2021 to 2025, and the consent agreement resolved that period of unlicensed operation by granting a money-transmitter licence, expiring December 31, 2026, conditioned on 1.9 million dollars in consumer redress for unhosted-wallet-linked fraud.

A related statutory thread confirms the durability of the licensing framework's companion identification duty: LD 1197, a 2025 bill that would have repealed the unhosted-wallet identification requirement at 32 M.R.S. section 6100-UU, died in committee on an Ought Not to Pass vote on May 28, 2025. That duty therefore remained in force throughout the period the Bitcoin Depot investigation was active and remains in force today, meaning the licensing and identification requirements operate as a single enforceable package rather than as separable obligations.

Outlook

The near-term signal is whether Bitcoin Depot's licence is renewed when it expires December 31, 2026, and on what terms. Separately, the Bureau's statutorily-mandated kiosk-fraud report, due February 1, 2026, had not been located this cycle, and would provide further detail on the scale of unlicensed kiosk activity the Bureau has identified beyond the single resolved case.

1 earlier distinct update(s)
Periodic update · new data 2026-09-28

Crypto Licensing

Maine's crypto licensing perimeter runs through two connected instruments. The Money Transmission Modernization Act (32 M.R.S. c.79-A), effective August 9, 2024, requires that virtual currency business activity, including exchange, custody and kiosk operation, hold a Maine money-transmitter licence under the statute absent an applicable exemption. This is a general money-transmission licensing statute extended to cover virtual-currency activity, rather than a crypto-native licensing framework built from the ground up, which is itself an analytically relevant fact: Maine has chosen regulatory extension over bespoke crypto legislation.

Layered on top of that general perimeter, the Virtual Currency Kiosk Act specifically requires virtual currency kiosk operators to be licensed as a Maine money transmitter and to comply with daily transaction caps, fee-and-exchange-rate caps, and unhosted-wallet consumer safeguards. This cycle produced the clearest evidence yet that this licensing structure carries real enforcement teeth: Bitcoin Depot entered a $1.9 million consent agreement with the Bureau of Consumer Credit Protection over third-party scam losses inflicted through its kiosks, and agreed to fully comply with Maine money-transmitter licensing going forward. The settlement is a leading enforcement precedent under the kiosk regime and demonstrates that the licensing requirement is being actively supervised rather than merely codified.

The regime's traffic-light status remains amber rather than green specifically because it rests on a general money-transmission statute extended to cover crypto activity, rather than a crypto-native framework purpose-built for the sector's specific risks. Whether Maine will move toward more crypto-specific licensing provisions, or continue to rely on the extension model with kiosk-specific add-ons as needed, is not resolved by the evidence available this cycle. A remaining scope question, not yet independently verified, is how the MTMA's virtual-currency-business-activity definition under Bureau Rule Ch. 709 compares to the federal FinCEN money-services-business definition; any divergence there could create compliance gaps or overlaps for multi-state operators.

Outlook

Watch for further enforcement actions against other Maine-licensed kiosk operators under the Virtual Currency Kiosk Act, which would confirm whether the Bitcoin Depot settlement is the first of a pattern rather than an isolated case. Also watch for any Bureau guidance clarifying the scope divergence, if any, between the state virtual-currency-business-activity definition and the federal MSB definition, which would affect multi-state crypto licensing strategy.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (2)
  1. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — Virtual currency exchange, custody, and transmission businesses operating in Maine must obtain a money transmitter license under Maine's general money-transmission licensing law, administered via NMLS, as no bespoke crypto-asset license exists.retrieved M5bindingin force
  2. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — Whether specific carve-outs or de minimis exemptions from Maine's money transmitter law apply to virtual-currency businesses has not been independently verified against the primary statute in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Maine has not enacted its own digital-asset taxonomy. Consistent with the seed disambiguation, token characterisation for securities/commodities purposes is governed by federal SEC/CFTC jurisdiction, which itself remains in flux pending the CLARITY Act's Senate progress. Payment stablecoins compliant with the federal GENIUS Act are explicitly confirmed as non-securities.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3 · CoinDeskCoinDesk — Whether a digital asset is a security (SEC oversight) or a digital commodity (CFTC oversight) is determined under federal law; Maine has not enacted a state-specific token taxonomy, and the federal SEC/CFTC jurisdictional split remains actively debated in pending market-structure legislation.retrieved M4bindingin force
  2. T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — The federal GENIUS Act confirms that compliant payment stablecoins are not treated as securities, a classification that will govern within Maine absent a state carve-out.retrieved M4bindingenacted not yet effective
  3. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — Maine has not enacted its own statutory taxonomy classifying digital assets (e.g., utility token vs. security token) distinct from federal characterization.retrieved M3non-bindinga fact about the regime

#

Maine has no state-specific statute addressing mining, staking, DeFi lending, node operation, or validator activity. The only applicable interpretive framework is federal FinCEN BSA/MSB guidance, which addresses when mining or exchange activity triggers money-transmitter status. Staking and DeFi lending remain unaddressed at both state and (largely) federal statutory level.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — Under federal FinCEN guidance, a person who mines convertible virtual currency solely for their own use is not acting as a money transmitter on that basis alone; this federal interpretation applies to mining activity conducted in Maine absent a state-specific override.retrieved M3bindingin force
  2. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — No Maine-specific statute or guidance addressing the licensing or supervisory treatment of staking activity has been identified.retrieved M2non-bindinga fact about the regime
  3. T4 · The BlockThe Block — No Maine-specific statute or guidance addressing DeFi lending platforms has been identified; federal market-structure legislation covering DeFi oversight remains in draft/study form.retrieved M2non-bindingexpected to resolve as the cycle horizon moves

#

Maine has not enacted a state-specific stablecoin statute. The controlling framework is the federal GENIUS Act, signed into law July 18, 2025, which establishes reserve, redemption, disclosure, and issuer-authorisation requirements for payment stablecoins nationwide, including for entities operating in Maine. The Act's substantive provisions are enacted but not yet effective; the statutory effective date is the earlier of January 18, 2027 or 120 days after federal regulators finalize implementing rules, and regulators have already missed the one-year rulemaking deadline. It is unverified whether Maine intends to pursue state-level certification as 'substantially similar' to the federal regime (a pathway New York is actively pursuing).

Standing sub-brief · as of 11 October 2026212 words · last cycle 2026-10-11

Stablecoin Regime

Maine has no dedicated stablecoin-specific statute, but the Virtual-Currency Unclaimed Property Act, P.L. 2025 chapter 675, which took effect July 29, 2026, brings virtual currency, including stablecoins under Maine's functional 'virtual currency' definition in 32 M.R.S. chapter 80, within the state's general unclaimed-property regime. Under this instrument, virtual currency held by a holder is subject to the state's existing rules on presumed abandonment, custody, liquidation and owner notice and recovery, the same framework that governs dormant bank accounts and other unclaimed financial assets. This is a new compliance obligation for any virtual-currency custodian or holder with dormant Maine-linked balances, running alongside, rather than replacing, the money-transmission licensing regime.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T4 · The BlockThe Block — Under the federal GENIUS Act, payment stablecoin issuers must maintain one-to-one reserves in eligible liquid assets such as U.S. dollars or short-term Treasuries.retrieved M5bindingenacted not yet effective
  2. T4 · The BlockThe Block — The GENIUS Act requires payment stablecoin issuers to publish redemption policies and provide holders with a defined redemption mechanism.retrieved M4bindingenacted not yet effective
  3. T4 · The BlockThe Block — The GENIUS Act requires monthly public disclosure of reserve composition by payment stablecoin issuers.retrieved M4bindingenacted not yet effective
  4. T4 · The BlockThe Block — Only federally chartered banks, OCC-supervised nonbank issuers, and state-qualified issuers operating under a state regime certified as substantially similar to the federal framework may issue payment stablecoins under the GENIUS Act.retrieved M5bindingenacted not yet effective
  5. T4 · The BlockThe Block — It has not been verified whether Maine intends to seek certification of a state-level stablecoin regime as 'substantially similar' to the federal GENIUS Act framework, a pathway some states are actively pursuing.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

No crypto-specific consumer-protection statute has been identified for Maine. General MSB/money-transmitter consumer protections (bonding, licensee verification via NMLS) apply by extension, but whether Maine's law imposes crypto-specific custody segregation or safeguarding duties has not been independently verified.

Standing sub-brief · as of 25 August 2026375 words · last cycle 2026-10-18

Consumer Protection

Maine money transmitters handling crypto self-transfers must now verify that a destination digital wallet actually belongs to the customer before completing the transaction, a first-in-the-nation control aimed at self-transfer fraud scripts. Virtual currency kiosk operators must also cap fees at the greater of $5 or 3% of the transaction amount, limit daily customer transactions to $1,000, and provide fraud refunds under the state's kiosk consumer-protection rules.

Periodic update · new data 2026-10-18

Consumer Protection

Maine's crypto-specific consumer protections are concentrated in two instruments: the Virtual Currency Kiosk Act (32 M.R.S. c.80 subch.4) and the Maine Revised Unclaimed Property Act as amended by P.L. 2025, c.675. The Kiosk Act requires kiosk operators to provide clear and conspicuous disclosure of material risks, including the risk of fraud or loss, as well as disclosure of the exchange rates charged to the customer. This is a point-of-transaction protection, aimed at the moment a consumer initiates a virtual-currency purchase or sale through a physical kiosk, and it sits within the Kiosk Act's broader licensing and transaction-limit framework.

The practical force of the disclosure duty is illustrated by the January 2026 enforcement action against Bitcoin Depot. The Maine Bureau of Consumer Credit Protection reached a consent agreement under which Bitcoin Depot agreed to pay 1.9 million dollars to compensate consumers who were defrauded by third-party scammers operating through its kiosks. As part of the agreement, the operator committed to comply with money-transmitter-licensing requirements and with provisions addressing unhosted wallets going forward. The action demonstrates that the disclosure and licensing requirements attaching to kiosk operation carry real supervisory consequence rather than standing as unenforced statutory text, and it is the clearest evidence available this cycle of the Bureau's active posture toward the kiosk channel specifically.

A separate, non-disclosure protection reaches consumers after a transaction has concluded. The amended Unclaimed Property Act requires kiosk operators to retain transaction records for not less than three years and adds virtual currency as a distinct unclaimed-property category, carrying a five-year dormancy period before holdings are treated as unclaimed. This extends a measure of consumer protection into the custody and recordkeeping space, though it is a record-retention and property-disposition rule rather than a market-conduct or custody-standard regime of general application.

Taken together, these instruments show a consumer-protection regime that is real but narrow in scope: it governs the kiosk interface and the post-transaction record and unclaimed-property period, while a broader custody, disclosure, or market-abuse regime covering non-kiosk virtual-currency business activity has not been identified. Two questions remain open as to the Bureau's further guidance and as to unhosted-wallet treatment beyond the Bitcoin Depot agreement's own reference to that term.

Outlook

The near-term trajectory for this module is incremental rather than structural: further Bureau of Consumer Credit Protection guidance on custody of client crypto assets by licensed money transmitters, and any clarification of unhosted-wallet treatment beyond the Bitcoin Depot consent agreement, are the two developments most likely to move this module's standing. Additional kiosk-sector enforcement, should it occur, would also be a signal worth tracking given the precedent set by the Bitcoin Depot settlement.

2 earlier distinct update(s)
Periodic update · new data 2026-10-11

Consumer Protection

Maine's Virtual Currency Kiosk Act, at 32 M.R.S. sections 6165 through 6170-B, imposes a specific set of consumer-protection caps and disclosure duties on kiosk operators: a 1,000-dollar daily transaction cap per customer, a fee cap set at the greater of 5 dollars or 3 percent of transaction value, mandatory risk disclosures and transaction receipts, and a minimum three-year transaction-record retention requirement. These provisions have been in force since June 12, 2025. The Bitcoin Depot consent agreement, effective January 5, 2026, is the first documented instance of these consumer-protection provisions being enforced in combination with the licensing requirement, since the underlying investigation concerned consumer fraud carried out through unlicensed kiosks operating outside this protective framework entirely.

No Maine-specific custody or segregation-of-client-crypto-assets rule distinct from the general Money Transmission Modernization Act's customer-funds provisions has been located; crypto-specific custody protection in Maine currently rests on the general money-transmission customer-funds framework rather than a dedicated crypto-custody statute.

Outlook

The Bitcoin Depot case demonstrates that the kiosk-specific consumer caps are being actively enforced against operators who fell outside the licensed perimeter; whether the Bureau applies the same caps and disclosure standards proactively to currently-licensed kiosk operators, rather than only reactively following a fraud investigation, is an open question for future cycles.

Periodic update · new data 2026-09-28

Consumer Protection

Maine's crypto consumer-protection regime escalated materially this cycle. The Virtual Currency Kiosk Act's unhosted-wallet provision, codified at 32 M.R.S. §§6163-6170-B, requires money transmitters to employ technologies ensuring that Maine consumers own and control their virtual wallets, a custody-safeguard requirement aimed directly at kiosk-enabled fraud where victims lose control of funds the moment they are converted to an irreversible crypto transfer. The Act separately provides a redress mechanism for consumers defrauded via kiosk transactions, and that mechanism has now been exercised: the Bureau of Consumer Credit Protection's $1.9 million consent agreement with Bitcoin Depot delivers restitution to Maine consumers harmed by third-party scams operating through the company's kiosk network.

This combination, an active statutory safeguard plus a demonstrated enforcement outcome delivering real restitution, is why the module's traffic-light status moved to green this cycle: the statute is not merely on the books but has been shown to function as intended, addressing what the evidence indicates is the dominant Maine crypto-consumer-harm typology, namely third-party scam-induced kiosk deposits. This stands in useful analytical contrast to the crypto_licensing module's amber status, which reflects that the underlying licensing framework is a general money-transmission statute extended to crypto rather than a purpose-built crypto licensing regime; the consumer_protection module's green status reflects specifically that the kiosk-targeted safeguards, however achieved, are working as designed.

An open question limits full confidence in the durability of this green assessment: PL 2025, c.285 required the Superintendent to submit a report of findings and recommendations on kiosk-customer fraud protection by February 1, 2026, and that report's publication status was not located this cycle. Its findings would clarify whether the Bitcoin Depot case is representative of a broader kiosk-fraud pattern across Maine's licensed kiosk population, or an isolated case that happened to reach settlement first among several possible candidates.

Outlook

Publication of the Superintendent's mandated kiosk-fraud report is the key near-term development to track; it would either confirm the redress mechanism is addressing a systemic problem at proportionate scale, or suggest the mechanism needs to be applied more broadly across additional kiosk operators. Any further enforcement actions applying the Kiosk Act's redress provisions to operators beyond Bitcoin Depot would also reinforce the module's current green trajectory.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (2)
  1. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — Consumers can verify the licensing status of a Maine-based virtual currency or money transmission business through the NMLS Consumer Access public licensee lookup tool.retrieved M2non-binding
  2. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — Whether Maine's money transmitter law imposes crypto-specific custody segregation or safeguarding requirements beyond generic MSB bonding/net-worth rules has not been independently verified against the primary statute.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

No Maine-specific statute addressing the tax treatment of digital assets has been identified. Maine individual income tax generally conforms to federal adjusted gross income, so federal capital-gains treatment of crypto disposals likely carries through, but this has not been independently verified. A federal discussion draft (Digital Asset PARITY Act) proposing a small-dollar stablecoin capital-gains safe harbor remains unenacted.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T4 · The BlockThe Block — No Maine-specific statute addressing capital gains tax treatment of digital assets has been identified; Maine individual income tax generally follows federal adjusted gross income, so federal capital-gains treatment of crypto disposals likely carries through absent a state-specific rule.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
  2. T4 · The BlockThe Block — A federal legislative discussion draft, the Digital Asset PARITY Act, would create a de minimis capital-gains safe harbor for small stablecoin transactions, but it has not been enacted as of August 2026.retrieved M2non-bindingexpected to resolve as the cycle horizon moves

#

No Maine-specific statute addresses cross-border crypto-asset transfers. The applicable framework is entirely federal: the BSA Funds Travel Rule and OFAC sanctions-screening obligations bind convertible-virtual-currency money transmitters doing business in Maine. No additional state-level outbound restriction has been identified.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — Federal FinCEN Funds Travel Rule obligations under 31 CFR §1010.410(f) apply to convertible-virtual-currency money transmitters doing business in Maine, requiring transmittal-order information to travel with qualifying fund transfers.retrieved M4bindingin force
  2. T1 · Financial Crimes Enforcement Network (FinCEN)Financial Crimes Enforcement Network (FinCEN) — OFAC sanctions programs apply to digital-currency transactions, and covered persons must screen virtual-currency addresses associated with sanctioned parties, a federal obligation binding on Maine-based crypto businesses.retrieved M4bindingin force
  3. T1 · Nationwide Multistate Licensing System / Conference of State Bank SupervisorsNationwide Multistate Licensing System / Conference of State Bank Supervisors — No Maine-specific state-level outbound restriction on cross-border crypto-asset transfers beyond the federal BSA/OFAC framework has been identified.retrieved M2non-bindinga fact about the regime

#

## Commercial Activity Bitcoin Depot Operating, LLC, headquartered in Atlanta, Georgia, was granted a Maine money-transmitter licence as part of a consent agreement with the Bureau of Consumer Credit Protection settling consumer-fraud claims for 1.9 million dollars, effective January 5, 2026, with the licence expiring December 31, 2026. The commercial structure of the agreement combines a path into the regulated market, via licensure, with a financial redress obligation tied to specific identified consumer harm from unhosted-wallet-linked kiosk fraud occurring while the company operated unlicensed between 2021 and 2025. This is the most material commercial-regulatory event involving a crypto-asset firm in Maine this cycle, both for its financial scale and because it resolves a multi-year unlicensed-operation period through negotiated settlement rather than contested enforcement litigation, giving the company continued market access conditioned on licence compliance through the end of 2026. ## Outlook Whether Bitcoin Depot's licence is renewed beyond December 31, 2026, and under what terms, will be the clearest signal of whether this consent agreement served as a durable entry into Maine's regulated kiosk market or a time-limited settlement.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T1Bitcoin Depot Operating, LLC — Commercial/regulatory event: Bitcoin Depot Operating, LLC (Atlanta, GA HQ) granted a Maine money-transmitter licence as part of a consent agreement settling consumer-fraud claims for $1.9M, effective 2026-01-05, licence expiring 2026-12-31.retrieved M4bindingin forcenew
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