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Maryland, USA
US-MDschema crypto-v2.0.0trajectory: not yet assessedregulatedoverlaps: FIM, WPM
Last updated · 8 categories · 12 sourced
findings · 23 sources in the cumulative register
8Categoriesbaseline.
12Findings.claims[]
7Tier-1 sourcesrun_metadata.t1_source_count
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Jurisdiction lead brief
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-brief312 words · last cycle 2026-09-21
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.
For an operator assessing Maryland's crypto-licensing perimeter, the practical requirement is straightforward but comprehensive: both the kiosk operator itself and each individual kiosk device must be separately registered with OFR via NMLS. This device-level registration granularity is more granular than a simple company-level licensing requirement, meaning an operator deploying multiple kiosks across Maryland must register each deployed unit rather than relying on a single company-wide registration. The regime's permanent adoption as of March 30, 2026 indicates the registration requirement is now settled state policy rather than a temporary or emergency measure. SB 741's removal of the prior ATM exclusion is analytically significant because it closes what had been the primary avenue by which a virtual-currency kiosk could avoid registration: software-based deployment models that did not resemble a traditional physical ATM. From October 1, 2026, that avenue closes, and the registration perimeter becomes functionally comprehensive across both hardware- and software-based kiosk deployment models operating in Maryland.
Outlook
The October 1, 2026 effective date for SB 741's broadened scope is the next concrete licensing milestone: software-based kiosk deployers not previously captured by the ATM-centric registration regime will become subject to the same registration obligation as hardware kiosk operators from that date.
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.
T4 · 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 M5bindingin force
T4 · 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 M3non-binding
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 M3non-bindinga fact about the regime
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-brief110 words · last cycle 2026-09-21
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.
Outlook
Whether SB 759/HB 859 advances, is amended, or dies in a future session will determine whether Maryland's on-chain activity regime gains a dedicated staking carve-out or continues to apply the general Securities Act test to staking-as-a-service activity.
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 M2non-bindinga fact about the regime
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-brief179 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.
Outlook
Watch for OFR's implementing regulations, which will determine the operational detail of both the state-issuer authorization pathway and the bank/credit-union notification requirement. The framework's confirmed effective date remains an open item pending primary-source confirmation.
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 M4bindingenacted not yet effective
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-brief79 words · last cycle 2026-08-21
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
Watch for whether OFR publishes any further consumer-facing fraud advisories or enforcement statistics tied to the 'pig butchering' typology as the kiosk-registration regime matures.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
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 M3non-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 M3non-bindingour coverage gap, expected to resolve on a re-run
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)
T4 · 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 M4bindingin force
T4 · 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 M4bindingin force
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.
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)
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 M2non-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 M4bindingin force
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.
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
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