Maryland, USA

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

Last updated 2026-10-13 · 8 categories · 12 sourced findings · 33 sources in the cumulative register

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

Jurisdiction lead brief

Latest update · 13 October 2026

Lead Signal

Maryland's crypto-licensing perimeter tightened with the commencement, on October 1, 2026, of two amendments to its virtual-currency kiosk framework. Chapter 417 (SB741) broadens the statutory definition of virtual currency kiosk operator to include a person who installs or operates software enabling a stand-alone automated device to provide virtual-currency services. This moves the obliged-entity line beyond the party that physically operates a kiosk to reach the software layer that makes a kiosk functional, materially widening the population subject to the Office of Financial Regulation's (OFR) kiosk registration regime. On the same date, Chapter 20/21 (HB118/SB261) took effect, excluding a payors payroll-processing agent from the Maryland Money Transmission Act's money-transmitter definition where three statutory conditions are met; this is a licensing-scope change with no direct digital-asset nexus but is administered by the same regulator and commenced on the same date, illustrating a broader pattern of OFR recalibrating definitional boundaries across its payments and digital-asset remit concurrently.

Other Developments

A municipal consumer-protection suit names Coinbase Financial Markets as a co-defendant. The City of Baltimore filed a complaint in Baltimore City Circuit Court on August 13, 2026, naming Coinbase Financial Markets, alongside Robinhood and Webull, as a co-defendant in the City's suit against Kalshi and KalshiEX LLC, alleging unlicensed sports-wagering distribution under Baltimore's Consumer Protection Ordinance. This is a municipal action, not a state OFR or Maryland Attorney General enforcement matter, and it is at the complaint stage with no ruling. The underlying theory concerns distribution of sports-event contracts rather than crypto-asset conduct specifically, though a major exchange's inclusion as co-defendant is a notable consumer-protection signal for Maryland's crypto-adjacent prediction-market intersection.

Maryland's stablecoin certification regime remains enacted but not yet operative, and its status is unchanged this cycle. No development in token classification, on-chain activity, tax treatment, cross-border transfer, AML/CFT, or crypto-sector commercial activity met the threshold for inclusion this cycle.

Cross-Monitor Connections

The kiosk-operator broadening connects directly to financial-integrity typology work on cash-to-crypto conversion channels, where physical kiosks are a recurring point of interest; widening Maryland's definition to capture the software-enabling layer closes a potential gap through which an installer could previously have argued they fell outside the operator definition. The Baltimore municipal suit against Kalshi, Coinbase, Robinhood, and Webull touches world-payments' merchant-acquiring and consumer-protection domains to the extent it concerns distribution channels for event-contract products, though the crypto-specific angle here is limited to Coinbase's inclusion as a named party rather than any crypto-asset-specific allegation.

Outlook

The near-term question for crypto licensing is whether OFR issues implementing guidance clarifying how the broadened kiosk-operator definition applies to software vendors who do not themselves own or operate kiosk hardware. For consumer protection, the Baltimore suit against Coinbase and its co-defendants remains at an early litigation stage; whether it progresses beyond the complaint, and whether any ruling touches on crypto-asset-adjacent distribution specifically, is the item to monitor. The Maryland Stablecoin Act's January 1, 2027 commencement, as scheduled, remains the most structurally significant horizon item for this jurisdiction's digital-asset regime, though it had no activity this cycle.

2 earlier updates not shown here.

Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Maryland's crypto-regulatory build-out advanced on two fronts this cycle: consumer-facing kiosk oversight tightened, and a state stablecoin framework was established. The Office of the Commissioner of Financial Regulation (OFR) requires virtual-currency-kiosk operators to register each kiosk with the Commissioner through the Nationwide Multistate Licensing System, a mandatory registration obligation in force under COMAR 09.03.16 since January 1, 2026 and adopted on a permanent basis effective March 30, 2026. SB 741 separately expands the definition of a virtual currency kiosk operator to include software-based kiosk deployers and removes the prior automated-teller-machine exclusion, with that broadened scope taking effect October 1, 2026. In parallel, the Maryland Stablecoin Act establishes OFR as the state regulator for entities seeking to serve as state issuers of stablecoins or providers of payment stablecoin services, and separately requires commercial banks and credit unions to notify the OFR Commissioner before seeking federal approval to become a permitted payment stablecoin issuer or to offer payment-stablecoin-related services. Both stablecoin provisions are enacted but not yet effective, with an effective date awaiting confirmation from a primary source. This bifurcated posture — tightening registration obligations for consumer-facing kiosks alongside a liberalising stablecoin-issuance framework — reflects a regulator calibrating differently across product types rather than moving uniformly in either direction; OFR is simultaneously the registrar for virtual-currency kiosks and the newly designated state regulator for payment-stablecoin issuance. This mixed picture is consistent with an overall in-transition jurisdiction status for Maryland's digital-asset regulatory perimeter.

Other Developments

Consumer-fraud driver identified. OFR's own January 15, 2026 legislative briefing identified a surge in Bitcoin-ATM 'pig butchering' scams as a driver for the expanded virtual-currency-kiosk oversight described above, an explicit, regulator-stated rationale for the registration build-out rather than an inferred one. Staking exemption proposed, status unresolved. SB 759/HB 859, the Maryland Financial Innovation Act of 2026, would exclude staking-as-a-service from Maryland Securities Act filing and registration requirements; the bill does not appear on OFR's list of enacted 2026 laws, and its final disposition remains unconfirmed this cycle. Both developments were sourced to Tier-1 OFR materials at High confidence, giving this cycle's consumer-protection and licensing signal a strong evidentiary basis; the staking-exemption item, by contrast, is sourced to a Tier-4 bill-tracking aggregator at Assessed confidence, reflecting the comparatively weaker sourcing available for an unresolved legislative proposal.

Cross-Monitor Connections

The virtual-currency-kiosk registration regime and Maryland Stablecoin Act each carry financial-integrity and payments-monitor relevance beyond this monitor's digital-asset-specific reading: the AML/CFT dimension of the kiosk and stablecoin-notification requirements is addressed in the financial-integrity monitor's subscribed slot for this jurisdiction, and the licensing/market-access dimension of the kiosk regime is a subject the world-payments monitor tracks under its own licensing module. Readers seeking the AML/CFT-specific or payments-market-access-specific analysis of these same instruments should consult those monitors directly; the digital-asset regulatory-perimeter reading provided here is this monitor's own lens on the same underlying facts.

Outlook

Two items define the near-term crypto-regulatory horizon for Maryland. First, SB 741's kiosk-scope broadening takes effect October 1, 2026, at which point software-based kiosk deployers become subject to registration on the same basis as hardware kiosk operators. Second, OFR is expected to issue implementing regulations for the Maryland Stablecoin Act, with an internal/external stablecoin advisory-committee structure anticipated; that regulatory build-out remains pending. The unresolved status of SB 759/HB 859's staking exemption is the most consequential open question: OFR has itself identified a potential regulatory blind spot were the bill to be enacted as drafted, and its final disposition was not confirmed this cycle. Taken together, Maryland's crypto regulatory trajectory this cycle is best characterized as in transition: binding consumer-protection-driven kiosk obligations are already in force, a liberalising stablecoin framework is enacted but awaiting implementing detail, and a potentially deregulatory staking carve-out remains genuinely unresolved.

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Maryland has no bespoke crypto-asset licensing statute. <cite index="34-6,34-7">Any company that offers to exchange, administer, or maintain virtual currencies may be subject to state regulation and licensing, as well as federal regulation, and services that engage in converting, buying, selling or transmitting digital currencies must be registered as a money services business</cite>. Virtual-currency exchange, custody, and transmission businesses are therefore folded into Maryland's general Money Transmission Act (Financial Institutions Article) administered by the Office of the Commissioner of Financial Regulation (OCFR) via the NMLS licensing portal, rather than under a distinct crypto licence.

Standing sub-brief · as of 25 August 2026312 words · last cycle 2026-10-13

Crypto Licensing

Maryland requires virtual-currency-kiosk operators to register each kiosk with the Office of the Commissioner of Financial Regulation through the Nationwide Multistate Licensing System. This registration requirement has been mandatory since January 1, 2026 and was adopted on a permanent basis under COMAR 09.03.16 effective March 30, 2026. SB 741 expands the scope of this licensing regime by broadening the statutory definition of a virtual currency kiosk operator to capture software-based kiosk deployers, not merely physical automated-teller-machine-style kiosks, and by removing the regime's prior ATM exclusion outright; this broadened scope takes effect October 1, 2026. Together, these two instruments constitute Maryland's core crypto-licensing framework for kiosk-based virtual-currency activity, administered throughout by OFR.

Periodic update · new data 2026-10-13

Crypto Licensing

Maryland's crypto-licensing architecture tightened on October 1, 2026 with the commencement of Chapter 417 (SB741), which broadens the statutory definition of virtual currency kiosk operator. The amended definition now includes a person who installs or operates software that enables a stand-alone automated device to provide virtual-currency services, extending registration-trigger scope beyond the operator of the physical kiosk itself to the software-distribution layer. This is confirmed at Confirmed confidence against a Tier-1 primary legislative source, and represents a direct widening of the population subject to OFR's kiosk registration, consumer-protection, and fraud-refund regime under the Virtual Currency Kiosk statute.

Concurrently, and administered by the same regulator, Chapter 20/21 of 2026 (HB118/SB261) took effect, excluding a payors payroll-processing agent from the Maryland Money Transmission Act's money-transmitter definition where three statutory conditions are met. While payroll processing itself is not a crypto-specific activity, this carve-out is material to the licensing module because it narrows the money-transmitter perimeter that otherwise anchors Maryland's approach to virtual-currency transmission and custody activity; the Money Transmission Act's general licensing requirement, carried forward unchanged this cycle at Probable confidence from a Tier-3 source, continues to require a license for virtual-currency transmission or custody conducted on behalf of customers, with a surety bond of the greater of $150,000 or 100% of average daily Maryland liability, capped at $2,000,000.

The concurrence of a widening (kiosk) and a narrowing (payroll) within the same licensing module, on the same commencement date, reflects routine legislative recalibration rather than a single directional policy shift. No OFR implementing guidance has been located interpreting either amendment, which is recorded as an open gap for this module; firms affected by either change currently have only the amended statutory text to work from.

Outlook

The principal open question for this module is whether OFR issues a bulletin or interpretive guidance addressing the scope of the broadened kiosk-operator definition as applied to software vendors, and separately, construing the three conditions attached to the payroll-processor exclusion. Absent such guidance, affected populations remain in a self-assessment posture against the amended statute.

2 earlier distinct update(s)

Periodic update · new data 2026-09-28

Crypto Licensing

Maryland requires a person to register as a virtual currency kiosk Operator with the Commissioner through the Nationwide Multistate Licensing System before operating a virtual currency kiosk in Maryland after January 1, 2026, under COMAR 09.03.16. This registration regime layers on top of, rather than replaces, the general Maryland Money Transmission Act licensing backstop: absent the kiosk-specific carve-out, a person engaged in money transmission using virtual currencies in Maryland generally requires a Maryland Money Transmitter licence under Financial Institutions Article, Title 12, Subtitle 4, together with COMAR 09.03.16 for the kiosk channel specifically.

SB741, enacted as Chapter 417, broadens the statutory definition of virtual currency kiosk operator to include a person who installs or operates software enabling a stand-alone automated device to provide virtual currency services, effective October 1, 2026. This scope expansion closes a definitional gap that had left software-enabled, device-agnostic virtual-currency dispensing arrangements outside the registration perimeter that hardware kiosk operators have faced since the start of 2026, and it is the development driving the module's tightening trajectory this cycle.

Taken together, Maryland's crypto-licensing posture is best described as a narrow, kiosk-specific registration regime superimposed on general money-transmission licensing, rather than a comprehensive state crypto-asset licensing statute. The registration requirement, the general MTL backstop, and the imminent scope expansion together define the current licensing perimeter for virtual-currency kiosk and kiosk-adjacent activity in the state.

Outlook

October 1, 2026 is the key date: from that point, software-enabled stand-alone device operators become subject to the same NMLS registration requirement as hardware kiosk operators. Whether the Office of Financial Regulation will issue interpretive guidance clarifying which software-enablement arrangements fall within the broadened definition ahead of that date was not established this cycle.

Periodic update · new data 2026-09-22

Crypto Licensing

Maryland's crypto licensing baseline is settled and unchanged: virtual-currency exchange and custody businesses operating in the state must obtain a money-transmitter licence under the Maryland Money Transmission Act, administered by the Commissioner of Financial Regulation. This is a confirmed, in-force requirement carried forward from the standing record, with no bespoke digital-asset licensing category layered on top of the general money-transmission framework.

The live question this cycle sits at the margin of that framework rather than within it. SB759/HB859, the Maryland Financial Innovation Act of 2026, as amended and reprinted March 2, 2026, would add a new Subtitle 13 to the Financial Institutions Article prohibiting state or local agencies from separately regulating digital-asset staking activity. This is a probable-confidence finding: the legislative text has been read, but final enactment status was not independently confirmed this cycle, so the bill sits as a pending rather than settled development. If enacted, it would formally narrow the space in which Maryland's licensing regime could be extended to reach staking specifically, while leaving the underlying money-transmission licensing requirement for exchange and custody activity untouched.

Maryland also defers characterisation of tokens as securities or commodities to federal SEC and CFTC jurisdiction rather than adopting its own state-specific taxonomy, a confirmed but thinly-sourced baseline finding that reinforces the state's general pattern of relying on existing frameworks (money transmission, federal securities law) rather than building bespoke crypto-specific instruments. Taken together, Maryland's licensing posture for crypto businesses is one of settled general-law coverage for exchange and custody, with the one area of genuine legislative movement being the staking-specific preemption question still working its way through the General Assembly.

Outlook

The SB759/HB859 staking preemption is the item to track into the next cycle. An enactment decision, expected around 2026 Q4, would resolve the current uncertainty and either confirm or foreclose the possibility of Maryland-specific staking regulation at the state or local level. Absent enactment, the current settled money-transmission licensing baseline for exchange and custody businesses continues to govern, and no further movement on token classification is anticipated given the state's continued deference to federal characterisation.

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

Sources and findings (3)

UnsourcedSB759/HB859 — Would prohibit state or local agencies from separately regulating digital-asset staking activity.
T3 · CoinDeskCoinDesk — Businesses that exchange, administer, or transmit virtual currency to or from Maryland residents must be registered/licensed as a money services business/money transmitter under Maryland's general Money Transmission Act, administered through NMLS by the Office of the Commissioner of Financial Regulation, absent a Maryland-specific crypto exemption.retrieved 2026-08-06M5bindingin force
T3 · CoinDeskCoinDesk — The 2018 Maryland General Assembly bills (HB 1634 / SB 1068), titled the Financial Consumer Protection Act, proposed only a study/recommendation process on crypto regulation via the Financial Consumer Protection Commission; no subsequent bespoke Maryland crypto-licensing statute distinct from the general money-transmission regime has been confirmed as enacted.retrieved 2026-08-06M3non-binding

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Maryland has not adopted a state-level statutory taxonomy for crypto-assets. Per the injected disambiguation, token characterisation for securities purposes is governed by federal SEC/CFTC jurisdiction (see US JID) rather than by Maryland-specific rules. <cite index="87-1,87-2">The SEC provided interpretive guidance in 2026 on crypto assets under the federal securities laws, distinguishing digital commodities from other crypto asset categories</cite>, but this is a federal, not Maryland, classification scheme.

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 (1)

T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Maryland has not enacted a state-specific statutory taxonomy for crypto-assets; token characterisation as a security, commodity, or other instrument is determined exclusively under federal SEC and CFTC frameworks applicable nationwide, not by Maryland state law.retrieved 2026-08-06M3non-bindinga fact about the regime

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Maryland has not legislated specifically on staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. Any relevant guidance in this space (e.g., SEC staff statements on protocol staking and proof-of-work mining) originates at the federal level and does not create Maryland-specific obligations or exemptions.

Standing sub-brief · as of 25 August 2026110 words · last cycle 2026-09-28

On-Chain Activity Regime

Maryland's on-chain activity regime remains defined by the general application of the Maryland Securities Act's investment-contract test, with one proposed carve-out currently unresolved. SB 759/HB 859, the Maryland Financial Innovation Act of 2026, would exclude staking-as-a-service from Maryland Securities Act filing and registration requirements. The bill does not appear on OFR's list of enacted 2026 laws, and its final disposition beyond committee hearings could not be confirmed this cycle.

Periodic update · new data 2026-09-28

On-Chain Activity Regime

Maryland's on-chain activity regime is indirect and channel-specific rather than general: it arises from the kiosk fraud-prevention rules under COMAR 09.03.16 rather than from any standalone on-chain-activity statute. Effective March 30, 2026, virtual currency kiosk operators must implement wallet-use restrictions and screen for high-risk or sanctioned wallets using blockchain-analytics providers. This requirement targets the cash-to-crypto conversion point specifically, obligating kiosk operators to screen transactions against wallet-risk data before completing them, rather than imposing a general on-chain monitoring obligation on all virtual-currency activity touching Maryland.

Because the screening obligation is tied specifically to the kiosk channel, it does not extend to peer-to-peer on-chain activity, exchange-based trading, or other virtual-currency activity outside the kiosk context. The regime's coverage is therefore best understood as indirect: Maryland does not regulate on-chain activity as such, but does impose a wallet-screening control at one specific physical/software channel where fiat cash converts to virtual currency.

Outlook

As SB741's broadened kiosk-operator definition takes effect October 1, 2026, the wallet-screening obligation will extend to software-enabled stand-alone device operators previously outside the kiosk definition, expanding the practical reach of this indirect on-chain screening control without changing its channel-specific character.

1 earlier distinct update(s)

Periodic update · new data 2026-09-22

On-Chain Activity Regime

Maryland's on-chain activity regime remains largely undefined by state regulation, with the notable exception of the staking-specific question now working through the legislature. SB759, as introduced and amended, would bar Maryland agencies from imposing licensing or reporting obligations on digital-asset staking that are distinct from existing money-transmission or securities law. This is a probable-confidence finding grounded in the pending legislative text: it confirms, by way of the very act of legislating a preemption, that no separate state-level staking regime currently exists and that the legislature is moving to keep it that way rather than to build one.

Outside of staking, the picture is one of an unresearched gap rather than an affirmative regulatory position. DeFi lending, mining, node operation, validator activity, decentralized exchange operation, and tokenization had no source coverage this cycle, and no claim in the record asserts either that Maryland regulates these activities or that it has affirmatively declined to. This is flagged upstream as a structurally under-indexed vector: on-chain activity where no regulator has yet spoken is easy to under-report precisely because there is nothing to find, but that absence is itself information worth carrying forward rather than treating as settled silence.

The overall trajectory for this module is uncertain rather than stable, reflecting the fact that the one concrete legislative signal (SB759/HB859) addresses only a slice of the on-chain activity landscape and its own enactment status remains unconfirmed.

Outlook

Watch the same SB759/HB859 disposition tracked under crypto licensing, expected around 2026 Q4, for resolution of the staking-specific question. Beyond that, closing the coverage gap on DeFi, mining, node operation, validator, and tokenization activity in Maryland would require a dedicated research pass; nothing in this cycle's record supports either a regulated or unregulated finding for those categories specifically.

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

Sources and findings (1)

T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Maryland has no state-specific statute or regulation governing staking, DeFi lending, mining, node operation, validator activity, or tokenization; such activity is addressed, if at all, only through non-binding federal SEC/CFTC staff statements of general nationwide applicability.retrieved 2026-08-06M2non-bindinga fact about the regime

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Maryland has no state-level stablecoin issuance-authorisation, reserve, or redemption regime. The federal GENIUS Act establishes the primary payment-stablecoin framework applicable nationwide, including to Maryland-domiciled issuers. <cite index="97-13">The GENIUS Act will become effective on the earlier of 18 months after its date of enactment (July 18, 2025) or the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue</cite> implementing rules, meaning the federal regime is still phasing in as of this research date.

Standing sub-brief · as of 25 August 2026179 words · last cycle 2026-08-21

Stablecoin Regime

The Maryland Stablecoin Act establishes OFR as the state regulator for entities seeking to serve as state issuers of stablecoins or providers of payment stablecoin services, a framework signed into law May 12, 2026. Separately, the Act requires commercial banks and credit unions to notify the OFR Commissioner before seeking federal approval to become a permitted payment stablecoin issuer or to offer payment-stablecoin-related services. Both provisions are enacted but not yet effective, with a confirmed effective date awaiting a primary source; OFR is expected to issue implementing regulations and stand up stablecoin advisory-committee structures as part of the framework's roll-out. This establishes a defined regulatory pathway and designated supervisor for stablecoin activity where none existed in Maryland before this cycle, positioning the state's banks and credit unions to engage with the federal GENIUS Act framework under an added layer of state-level notification.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (1)

T1 · U.S. Securities and Exchange CommissionU.S. Securities and Exchange Commission — Maryland has no independent stablecoin issuance-authorisation regime; payment-stablecoin issuance is governed federally by the GENIUS Act, which becomes fully effective on the earlier of 18 months after its July 18, 2025 enactment or 120 days after primary federal regulators issue implementing rules.retrieved 2026-08-06M4bindingenacted not yet effective

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Maryland relies on general state consumer-protection law and the bonding/customer-fund provisions embedded in its general Money Transmission Act rather than any crypto-specific statute. Unlike several peer states, no Maryland-specific crypto-ATM/kiosk consumer-protection law (fee caps, transaction limits, fraud warnings) has been confirmed as enacted. <cite index="65-6,65-7">Illinois Governor JB Pritzker signed the Digital Asset Kiosk Act (SB 2319), which requires kiosk operators to register with state regulators, establish live customer service, and cap transaction fees at 18%, with daily transactions for new customers limited to $2,500</cite> — illustrating the type of regime Maryland has not been confirmed to have adopted. Federally, <cite index="61-3">in 2024, the FBI's IC3 received more than 10,956 complaints reporting the use of CVC kiosks, with reported victim losses of approximately $246.7 million</cite>, underscoring the fraud-risk backdrop against which Maryland's silence on kiosk-specific rules should be read.

Standing sub-brief · as of 25 August 202679 words · last cycle 2026-10-13

Consumer Protection

OFR's January 15, 2026 legislative briefing identified a surge in Bitcoin-ATM 'pig butchering' scams as the driver behind Maryland's expanded virtual-currency-kiosk registration oversight. This is a non-binding regulatory briefing statement rather than a standalone consumer-protection statute, but it is the explicit, regulator-stated rationale for the kiosk-registration build-out addressed under Crypto Licensing above.

Outlook

Periodic update · new data 2026-10-13

Consumer Protection

A Baltimore City Circuit Court complaint, filed August 13, 2026, names Coinbase Financial Markets as a co-defendant, alongside Robinhood and Webull, in the City of Baltimore's suit against Kalshi and KalshiEX LLC. The complaint alleges unlicensed distribution of sports-event contracts in violation of Baltimore's Consumer Protection Ordinance. This finding is carried at Probable confidence from a Tier-3 source, reflecting the early stage of the litigation and the absence of any judicial ruling to date.

The matter is notable for this module chiefly because of its jurisdictional character: it is a municipal action brought by the City of Baltimore, not a state-level action by the Maryland Office of the Attorney General's Consumer Protection Division or by OFR, which is the usual locus of Maryland crypto-sector consumer-protection enforcement. The underlying legal theory concerns unlicensed sports-wagering-adjacent distribution of event contracts rather than any crypto-asset-specific conduct by Coinbase; Coinbase's inclusion as a co-defendant alongside Robinhood and Webull reflects its role as a distribution platform for the contracts at issue rather than an allegation tied to its crypto-asset business lines.

No ruling, motion outcome, or settlement has been identified as of this cycle. Whether the suit progresses, whether Coinbase remains a co-defendant through any dispositive motion, and whether any ruling addresses the licensing-status question for event-contract distribution on crypto-exchange-affiliated platforms are all open questions for subsequent cycles. No other Maryland crypto-specific consumer-protection development, complaint, or enforcement action has been identified this cycle.

Outlook

The litigation is at an early stage and its trajectory is uncertain. The item to monitor is whether the Baltimore City Circuit Court rules on any motion to dismiss, and whether the City's theory of unlicensed distribution is tested against Coinbase's specific role as a distribution channel for the contracts at issue, as distinct from Kalshi and KalshiEX's role as the contract issuer.

1 earlier distinct update(s)

Periodic update · new data 2026-09-28

Consumer Protection

Maryland's COMAR 09.03.16 kiosk rules layer a detailed, in-force consumer-protection rulebook onto the virtual currency kiosk channel. Operators are prohibited from charging users for fraud investigations, from requiring a police report to process refund claims, and from using certain prohibited factors to deny refunds. These protections address specific harms associated with kiosk-based virtual-currency transactions, including scam-related losses and disputed refund claims, and they operate as binding, in-force conditions on kiosk operators rather than as guidance or best-practice recommendations.

This rulebook is specific to the kiosk channel rather than a general crypto-consumer-protection statute applicable to all virtual-currency activity in Maryland; exchange-based trading, peer-to-peer transactions, and other non-kiosk virtual-currency activity are not covered by these particular provisions. The regime's specificity reflects the particular fraud-risk profile associated with kiosk-based cash-to-crypto conversion, where scam victims are frequently directed to complete a kiosk transaction as part of a broader fraud scheme.

Outlook

As the kiosk-operator definition broadens to cover software-enabled stand-alone devices from October 1, 2026, these consumer-protection obligations will extend to that broader population of operators, meaning the refund-protection and fraud-investigation-charge prohibitions will apply to any qualifying software-enabled kiosk deployment in Maryland from that date.

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

Sources and findings (2)

T4 · The BlockThe Block — Unlike peer states that have enacted crypto-ATM/kiosk consumer-protection statutes (e.g., Illinois's Digital Asset Kiosk Act, North Dakota's HB 1447, Minnesota's 2024 kiosk-disclosure law and subsequent SF 3868 ban), Maryland has not been confirmed to have enacted a kiosk-specific disclosure, fee-cap, or transaction-limit law as of this research date.retrieved 2026-08-06M3non-bindingour coverage gap, expected to resolve on a re-run
T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — Maryland-licensed money transmitters handling virtual currency are presumed subject to the general MTL regime's bonding and customer-fund permissible-investment/segregation requirements, but the specific Financial Institutions Article citation and its applicability to non-fiat virtual-currency holdings has not been independently confirmed in this research pass.retrieved 2026-08-06M3non-bindingour coverage gap, expected to resolve on a re-run

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Maryland has not enacted crypto-specific tax statutes and is understood to follow the federal characterisation of virtual currency as property for income tax purposes, since Maryland's income tax base starts from federal adjusted gross income; a Maryland Comptroller-specific digital-asset tax bulletin was not located in this research pass. Federally, <cite index="57-2">the U.S. Internal Revenue Service (IRS) in 2014 decided bitcoin and other cryptocurrencies should be treated as "property", meaning they qualify for capital gains treatment similar to traditional assets like stocks and bonds</cite>, and new broker-reporting obligations have recently taken effect: <cite index="53-4,53-5">for the first time, cryptocurrency exchanges will issue Form 1099-DA, a new document that declares cost basis and proceeds directly to the IRS, with brokers required to issue them by February 17, 2026, covering all sales and exchanges from 2025</cite>.

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)

T3 · CoinDeskCoinDesk — Since 2014 IRS guidance, virtual currency is treated as property for U.S. federal income tax purposes, so that dispositions of crypto-assets generate capital gains or losses; Maryland's income tax, computed from federal adjusted gross income, is presumed to follow this federal characterisation absent a confirmed state-specific override.retrieved 2026-08-06M4bindingin force
T3 · CoinDeskCoinDesk — Beginning with the 2025 tax year, crypto exchanges and brokers must issue IRS Form 1099-DA reporting cost basis and proceeds, with the first broker filings due by February 17, 2026 — a federal reporting obligation applicable to Maryland taxpayers as U.S. federal taxpayers.retrieved 2026-08-06M4bindingin force

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Maryland imposes no state-specific outbound restriction, reporting threshold, or travel-rule overlay on cross-border crypto transfers beyond the federal baseline. Cross-border virtual-currency transfers by Maryland persons/entities remain subject to federal OFAC sanctions and the FinCEN BSA travel-rule/reporting framework applicable nationwide. <cite index="40-2,40-3">OFAC designated Blender.io, which provided mixing services that were used by DPRK to launder over $20.5 million from the Axie Infinity Heist in May 2022, and also designated Tornado Cash, which provided mixing services that obfuscated the movement of over $455 million stolen in March 2022 by the OFAC-designated, North Korea-controlled Lazarus Group</cite>, illustrating the binding federal sanctions-nexus layer that applies regardless of Maryland's lack of a state-specific overlay.

Standing sub-brief · as of 28 September 2026208 words · last cycle 2026-09-28

Cross-Border Transfer

Maryland's most directly relevant development in this module is not a transfer-restriction regime but a custody and unclaimed-property obligation newly extended to virtual currency. Under Commercial Law Article §17-307.2, virtual currency is presumed abandoned if it remains unclaimed five years after the last indication of apparent owner interest, and holders must liquidate abandoned virtual currency within 30 days before filing the annual holder report. This creates a recurring annual compliance deadline for any entity holding virtual currency on behalf of Maryland consumers where owner contact has lapsed for the statutory period.

no periodic updates on record for this sub-brief

Sources and findings (2)

T2 · Conference of State Bank Supervisors / State Regulatory Registry LLCConference of State Bank Supervisors / State Regulatory Registry LLC — Maryland imposes no state-specific outbound restriction, reporting threshold, or travel-rule requirement on cross-border virtual-currency transfers beyond the federal BSA/FinCEN baseline applicable to all U.S. money transmitters.retrieved 2026-08-06M2non-bindinga fact about the regime
T1 · FinCENFinCEN — Cross-border virtual-currency transfers involving Maryland persons or entities remain subject to binding federal OFAC sanctions, as illustrated by OFAC's designations of virtual-currency mixing services (e.g., Blender.io, Tornado Cash) used to launder proceeds of major crypto heists.retrieved 2026-08-06M4bindingin force

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Crypto AML/CFT obligations applicable to Maryland-licensed virtual-currency money transmitters (BSA registration, travel rule, SAR filing, sanctions screening, recordkeeping) are governed by the federal Bank Secrecy Act / FinCEN MSB framework. Per fleet module-subscription doctrine, crypto subscribes to the shared Financial Integrity Module (FIM) `aml_ctf` baseline; no Maryland-specific AML/CFT claims are produced in this crypto DR baseline to avoid duplicative cross-consumer claims. Any AML-scope material surfaced during this research (e.g., FinCEN CVC-kiosk advisories) is disambiguation context only, not a crypto-baseline claim.

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`schema_valid`	pass
`min_quoted_text_present`	waived — floor 0%
`egress_verified`	pass
`every_practical_object_has_source_id`	FAIL
`source_tier_integrity_ok`	pass
`jurisdiction_source_floor_met`	pass
`tier_a_b_national_primary_pct`	57.14
`aggregator_only_jurisdiction_count`	0
`manual_override`

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Editorial metadata for Maryland, USA
Field	Value
`trust.lawyer_review.status`	never_reviewed
`trust.lawyer_review.reviewer`	no reviewer on record
`trust.content_source`	ai_generated

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Maryland, USA

Jurisdiction lead brief

Latest update · 13 October 2026

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Standing brief · as of 25 August 2026

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