title: United States – Maryland Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-maryland/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # United States – Maryland US-MD schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 65 sourced findings · 154 sources in the cumulative register 14 Modules baseline.modules[] 65 Findings modules[].findings[] 98 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) No modules moved this cycle. ** United States federal law** that applies in United States – Maryland is covered once, on the [United States](https://payments.gi/jurisdictions/united-states/) page. This page covers United States – Maryland’s own layer: its own law, regulators and enforcement. ## Jurisdiction brief ###### Latest update · 13 October 2026 #### Lead Signal Maryland's payments licensing perimeter moved in two directions on October 1, 2026 as two state instruments commenced simultaneously. Chapter 20/21 (HB118/SB261) excludes a payors payroll-processing agent from the Maryland Money Transmission Act's definition of money transmitter where three statutory conditions are met, reversing the Office of Financial Regulation's 2023 inclusion of payroll processors within licensing scope. The same date brought into force Chapter 417 (SB741), which broadens the definition of virtual currency kiosk operator to capture any person who installs or operates software enabling a stand-alone automated device to provide virtual-currency services. The combined effect is a licensing perimeter that narrows for one population of payments-adjacent service providers and widens for another, both administered by Maryland's Office of Financial Regulation (OFR) under the same statutory framework. For non-bank payment institutions and e-money-type operators licensed or seeking licensure in Maryland, the practical consequence is that payroll-processing arrangements meeting the statutory carve-out conditions no longer require money-transmitter licensure, while any party installing or operating kiosk-enabling software, not merely the operator of the physical device, now falls within the registration-required population under the kiosk statute. Neither change reflects a conduct, safeguarding, or financial-promotions development; both are market-access and licensing-scope questions, and both commenced without accompanying OFR implementing guidance. #### Other Developments **Maryland's surety bond requirement for money transmission is unchanged.** The statutory bond requirement, the greater of $150,000 or 100% of average daily Maryland money-transmission liability, capped at $2,000,000 under section 12-412, is carried forward this cycle as a confirmatory, no-change position; it was not independently re-verified against primary statute text this cycle but no contrary signal was found. **A thinly-sourced Maryland capital event fell below the evidentiary floor for this monitor.** A single Tier-4 aggregator reported that DataTribe, a Maryland-based cybersecurity venture firm, began raising a fourth fund in October 2026, with the amount undisclosed. This does not meet the two-independent-source floor applied to commercial-intelligence events and, more materially, DataTribe is not a payments- or fintech-native entity, so no qualifying W13 commercial event is recorded this cycle. #### Cross-Monitor Connections The virtual-currency kiosk broadening under Chapter 417 is the clearest point of contact with financial-crime monitoring: widening the population subject to OFR's kiosk registration, consumer-protection, and fraud-refund regime to include software installers and operators increases the number of regulated touchpoints for cash-to-crypto conversion through kiosks, a channel of standing interest to illicit-finance typology work. The payroll-processor exclusion under Chapter 20/21 has no comparable financial-crime nexus; it is a pure licensing-scope question. Both instruments are legislative, not enforcement-driven, consistent with routine state regulatory-calendar activity rather than a response to an identified incident. #### Outlook The near-term question for licensing and market-access purposes is whether OFR issues implementing guidance construing the three statutory conditions attached to the payroll-processor exclusion, and separately, how OFR intends to apply the broadened kiosk-operator definition to software vendors who do not themselves own or operate kiosk hardware. Absent such guidance, both the narrowed and the widened populations are left to self-assess against the amended statutory text directly. No further Maryland payments-licensing development is scheduled or anticipated in the near term beyond these two commenced instruments. _5 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Maryland has moved from a payments backwater to an active state-level laboratory this cycle, anchored by enactment of the Maryland Stablecoin Act (SB662/HB1355) on May 12, 2026, which establishes a state-issuer and payment-stablecoin-service-provider framework taking effect January 1, 2027. The Office of the Commissioner of Financial Regulation (OFR) is designated the state's stablecoin regulator, tasked with issuing GENIUS Act-modeled rules and standing up internal and external stablecoin committees. The timing is not incidental: federal Treasury rulemaking under the GENIUS Act requires state regimes seeking "substantially similar" status to match OCC-level reserve-asset and capital standards, meaning Maryland's implementing rules must be calibrated against a federal benchmark whose own rulemaking stage remains unresolved as of this retrieval date. Complementing the issuer framework, 2026 amendments to Maryland's nondepository trust-company charter, also carried in HB1355, ease capital-stock requirements and add disclosure mandates, creating the chartering vehicle a stablecoin issuer would actually use to operate in the state. A newly created Blockchain and Cryptocurrency Task Force, staffed by OFR, must report to the Governor and General Assembly by October 1, 2027, giving the implementation period a defined feedback loop. For payments operators, the practical read is that Maryland has positioned itself as an early mover on GENIUS Act-aligned state stablecoin regimes, though implementation regulations and the federal "substantially similar" calibration remain to be finalized before the January 2027 in-force date. #### Other Developments Maryland's conduct-and-safeguarding layer is tightening in parallel. Senate Bill 94, signed April 28, 2026, bans tipping in earned wage access products and mandates overdraft-fee reimbursement, but does not take effect until October 1, 2026 — until then, the operative EWA regime remains HB1294 (2025), which permits disclosed tipping. The same legislative package expands the 2023 Access to Banking Act via SB43/HB259, creating a collaborative model and Maryland Opportunity Accounts that channel fee credits to banks and credit unions serving unbanked and underbanked residents. Separately, finalized Virtual Currency Kiosk rules under COMAR 09.03.16 took effect January 13, 2026, imposing disclosure-timing, receipt-content, ATM-style physical-safety, sanctioned-wallet screening, and chief-compliance-officer designation requirements on kiosk operators. At the national-scheme level, the amended interchange settlement in In re Payment Card Interchange Fee and Merchant Discount Antitrust Litigation (MDL 1720) received court approval in June 2026, following an April 27 hearing before Judge Brian Cogan — a materially more advanced posture than the "proposed" framing earlier research carried. The settlement caps standard consumer credit interchange at 1.25% for eight years, freezes posted rates for five years, expands surcharging to 3%, and introduces a modified Honor All Cards regime under which merchants may decline higher-cost card tiers while still honoring all cards within an accepted tier. Maryland merchants remain subject to the pre-existing network surcharge caps of up to 4% (3% for Visa), as the state's 2024 attempt to legislate a true-cost-of-acceptance surcharge cap did not pass. On enforcement, OFR's active posture continued across multiple fronts. The Court of Special Appeals upheld a $5,651,000 penalty against CashCall Inc. for unlicensed "credit services business" activity spanning more than 5,000 Maryland loans priced up to 96% APR. A parallel appellate ruling in the Matter of Cash-N-Go, Inc. upheld Commissioner penalties and restitution against a licensed check-casher offering unlicensed loans disguised as title pawns. And OFR joined a multistate $80 million BSA/AML enforcement action against Block, Inc./Cash App, with Maryland's allocated share approximately $1.6 million. On the industry-structure side, M&T Bank remains the dominant regional bank presence touching Maryland's payments-adjacent landscape, serving more than 3.6 million clients across a nine-jurisdiction footprint. The Maryland Community Investment Venture (MCIV) Fund continues to anchor the state's fintech-bank partnership model, granting $25,000-$50,000 to fintechs partnering with state-chartered banks and credit unions for pilots without taking equity, and it extended its 2025 proposal deadline to January 31, 2026. Elsewhere in the digital-asset space, a new State Bitcoin Reserve Fund authorizes the state treasurer to invest gambling-enforcement proceeds in Bitcoin, while a bill to modernize Maryland's commercial code to recognize controllable electronic records under UCC Article 12 (SB154) appears not to have passed the 2026 session and is reportedly slated for resubmission in January 2027. #### Cross-Monitor Connections The Block, Inc./Cash App multistate settlement sits at the seam between this monitor and FIM: OFR's participation confirms a BSA/AML due-diligence failure was found and remedied through a coordinated multistate settlement, but the underlying illicit-finance analysis — sanctions-evasion exposure, enforcement-trend synthesis across states — belongs to FIM's Sentinel-fed AML/CFT coverage rather than to this monitor's payments-regulation lens. More broadly, Maryland's federal AML backbone requires every licensed money transmitter to register with FinCEN and maintain a written compliance program, a baseline obligation carried here as Sentinel-fed provenance pending direct integration of the proprietary feed. Maryland also has no payments-specific operational-resilience statute comparable to the EU's DORA; its resilience posture is instead assembled from the general Personal Information Protection Act breach-notification regime, insurance-sector cybersecurity-event reporting rules, and the federal Cyber Incident Reporting for Critical Infrastructure Act backstop — a persistent structural gap relative to EU/UK peers that this monitor will continue to track rather than resolve. #### Outlook Three dated milestones will define whether Maryland's liberalising trajectory converts into settled market access: the Stablecoin Act's January 1, 2027 in-force date and the Blockchain Task Force's October 1, 2027 report; the EWA tipping ban's October 1, 2026 in-force date; and the still-unresolved progression of Treasury's GENIUS Act "substantially similar" rulemaking, which will determine how far Maryland's regime must be recalibrated before it can claim federal-equivalence status. Until those dates land, Maryland sits in a liberalising-but-unproven posture: an early-mover legislative architecture for stablecoins and consumer protection, layered onto an OFR enforcement track record that shows no sign of slowing. trust tier: ai_unverified ###### Latest update · 6 October 2026 #### Regulatory Status Maryland's money transmission licensing perimeter has been narrowed by SB 261 (Ch. 21, 2026 RS), which excludes a person designated as an agent of a payor, for the purpose of the agent's provision of payroll-processing services, from the statutory definition of "money transmitter" under the Maryland Money Transmission Act, under certain circumstances. The exclusion is in force as of 1 October 2026. This corrects a prior record that had misattributed the same exemption to Montana under a similarly numbered bill; the instrument is confirmed as Maryland's own Chapter 21 enactment. No other Maryland payments module carried material movement in this period. #### Outlook The near-term question is the practical scope of the exclusion: which payroll-processing agent arrangements satisfy the "certain circumstances" the statute requires, and which remain subject to Maryland money transmitter licensing. That boundary has not yet been further researched. _3 earlier updates not shown here._ ###### Standing brief · as of 5 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Maryland enters this monitor's coverage as an ELEVATED-risk, liberalising jurisdiction: a state-issuer stablecoin regime, a permissive nondepository trust-company charter route, an active fintech-bank grant program, and a broadened consumer-protection statute book are advancing together, layered onto an OFR enforcement posture that shows no sign of slowing. The Maryland Stablecoin Act (SB662/HB1355), enacted May 12, 2026, establishes a state-issuer and payment-stablecoin-service-provider framework effective January 1, 2027, with OFR designated as regulator. The same 2026 legislative session eased nondepository trust-company capital-stock requirements, creating the chartering route a stablecoin issuer would use. Conduct and consumer-protection law tightened via Senate Bill 94, which bans earned-wage-access tipping and mandates overdraft-fee reimbursement effective October 1, 2026, and via an expanded Access to Banking Act channeling fee credits to banks serving unbanked residents. On the national-scheme side, Maryland merchants and acquirers became class members in the court-approved MDL 1720 interchange settlement, which caps standard consumer interchange and introduces a modified Honor All Cards regime. OFR's litigation and enforcement record — the CashCall and Cash-N-Go appellate precedents and the multistate Block/Cash App BSA/AML settlement — continues to expand independent of federal action. Two structural gaps persist: Maryland has no payments-specific operational-resilience statute comparable to the EU's DORA, and no distinct correspondent-banking statute, with both functions instead running through general breach law, federal CIRCIA, and OFR's federal-chartering gateway. #### Outlook Maryland's near-term regulatory calendar is unusually dense for a single state: the Stablecoin Act's January 1, 2027 in-force date, the Blockchain Task Force's October 1, 2027 report deadline, and the EWA tipping ban's October 1, 2026 in-force date all land within an eighteen-month window, while the federal GENIUS Act 'substantially similar' rulemaking that will calibrate Maryland's regime remains unresolved. Payments operators active in Maryland should treat this as a liberalising-but-unsettled jurisdiction: statutory architecture is advancing faster than implementing regulation, and the state's enforcement posture gives no indication that market-access flexibility will be paired with reduced supervisory scrutiny. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access Confirmed confirmed 2026-07-05 Maryland Money Transmission Act excludes a qualifying payor agent providing payroll-processing services from the statutory definition of money transmitter, per SB 261 (Ch. 21), effective 2026-10-01. Standing sub-brief · as of 5 July 2026 201 words · last cycle 2026-10-13 #### Licensing, Authorisation & Market Access Maryland's money transmission regime runs through the Financial Institutions Article, Title 12, Subtitle 4, which requires all money transmitters operating in the state to hold an OFR license and maintain a surety bond starting at $150,000 and scaling to $1,000,000 with transmission volume. OFR participates in the Multistate Money Services Businesses Licensing Agreement Program, streamlining licensure for firms seeking authorisation across five or more states simultaneously. This cycle's most consequential development is the finalized overhaul of COMAR 09.03.14, which modernises the money transmitter regime and adds an agent-of-the-payee exemption; a law-firm source dates the finalization to November 17 without specifying the year, and the primary Maryland Register text should be checked before this date is treated as settled. Separately, 2026 amendments to the nondepository trust-company charter under HB1355 ease capital-stock requirements and add disclosure mandates, creating the state-chartering vehicle a stablecoin issuer would use — directly linking this licensing infrastructure to the incoming Maryland Stablecoin Act. #### Outlook The licensing trajectory here is escalating: the trust-company charter route positions Maryland to onboard a stablecoin issuer ahead of the Act's January 2027 in-force date, while the COMAR 09.03.14 dating discrepancy remains a verification item to resolve before publication. Periodic update · new data 2026-10-13 #### Licensing, Authorisation & Market Access Maryland's licensing-and-market-access perimeter underwent two concurrent definitional changes effective October 1, 2026. Chapter 20 and Chapter 21 of 2026 (HB118/SB261) amend the Maryland Money Transmission Act's definition of money transmitter to exclude a payors payroll-processing agent, provided three statutory conditions are met. This is a licensing-exemption development: it reverses the Office of Financial Regulation's 2023 position bringing payroll processors within money-transmitter scope, and it removes a population of payroll-services providers from the licensing requirement entirely, subject to the stated conditions. For non-bank payment institutions and e-money-type operators structuring payroll-adjacent services in Maryland, this is a narrowing of the regulatory perimeter they must assess against. Concurrently, Chapter 417 of 2026 (SB741) broadens the definition of virtual currency kiosk operator to include a person who installs or operates software that enables a stand-alone automated device to provide virtual-currency services. This moves in the opposite direction from the payroll-processor change: it widens the population required to register under Maryland's kiosk-operator regime, reaching software-layer participants, installers and operators of enabling software, who may not themselves own or operate the physical kiosk hardware. Both amendments are administered by the same authority, OFR, and both commenced on the same date, but they affect entirely distinct populations: payroll-processing agents on one side, virtual-currency kiosk software participants on the other. A Tier-3 source carries forward, unchanged this cycle, Maryland's surety bond requirement for money transmission: the greater of $150,000 or 100% of average daily Maryland money-transmission liability, capped at $2,000,000 under section 12-412 of the Financial Institutions Article. This bond requirement applies to the broader money-transmitter population and was not independently re-verified against primary statutory text this cycle, but no change signal was identified either. No OFR implementing guidance or bulletin interpreting either the payroll-processor exclusion's three statutory conditions or the broadened kiosk-operator definition has been located as of this cycle. This is a material gap for market-access planning purposes: entities seeking to rely on the payroll exclusion, or attempting to determine whether their software-distribution activity now falls within the kiosk-operator definition, must currently work directly from the amended statutory text without an interpretive bulletin from the regulator. #### Outlook The most consequential open question for Maryland licensing and market access is whether OFR publishes guidance construing the three conditions attached to the payroll-processor exclusion and clarifying the scope of the broadened kiosk-operator definition as applied to software vendors rather than hardware operators. Absent such guidance, both populations remain in a self-assessment posture. No further licensing or market-access development specific to Maryland has been identified for the near-term horizon beyond these two commenced instruments; the Maryland Stablecoin Act's separate certification pathway, noted elsewhere in this monitor's standing trackers, remains enacted but not yet in force and is not treated as a current market-access development this cycle. **5 earlier distinct update(s)** Periodic update · new data 2026-10-06 #### Licensing, Authorisation & Market Access Maryland has enacted a targeted exclusion from its money transmission licensing perimeter. SB 261 (Ch. 21, 2026 RS) amends the definition of "money transmitter" under the Maryland Money Transmission Act to exclude a person designated as an agent of a payor, for the purpose of that agent's provision of payroll-processing services, under certain circumstances. The exclusion is now in force, with a legal effective date of 1 October 2026. For a payroll-processing agent that qualifies under the statute's terms, the consequence is that the activity in question falls outside the licensing requirement altogether, rather than being licensed on modified terms. This also stands as a correction to the Maryland record. The exemption had previously been recorded against Montana, under a similarly numbered SB 261 in that state's legislature; the measure is Maryland's, and the record now reflects Chapter 21 of Maryland's 2026 Regular Session as the correct instrument. Whether a corresponding duplicate entry on the Montana side has itself been independently corrected has not been verified, and is noted as an open item rather than resolved here. The statute's own terms leave open what exactly constitutes "certain circumstances" for the exclusion to apply, and what applicability thresholds, if any, attach to the agent-of-a-payor designation. Those boundary questions have not yet been researched and are not addressed in this record. #### Outlook With the exclusion in force from 1 October 2026, the open question for Maryland's money transmission perimeter is the scope of "certain circumstances" governing which payroll-processing agent arrangements actually qualify. Until that boundary is further clarified, payor-agent arrangements touching Maryland payroll processing sit in a narrowed but not fully delineated carve-out from licensing. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Maryland's money-transmission licensing perimeter narrowed slightly this cycle through SB261 (2026), which amends the Maryland Money Transmission Act to exempt agents of a payor that provide payroll-processing services from money-transmitter licensing. Prior to this amendment, an entity acting as an agent of a payor to process payroll could fall within the scope of activity requiring licensure as a money transmitter; SB261 removes that requirement for the payroll-processing use case specifically, rather than broadening any general exemption category. This is a liberalising development for firms operating in the payroll-processing space with a nexus to Maryland, since it removes a licensing requirement that would otherwise have applied to a defined class of agents. This sits on top of Maryland's existing licensing-administration architecture, under which the Office of the Commissioner of Financial Regulation has, since July 1, 2023, administered money-transmitter licences on a principal-office basis: individual licences for locations other than the principal executive office are not required and are not issued. Firms holding a Maryland money-transmitter licence disclose additional operating locations under that single principal-office licence rather than obtaining separate per-location licences, a structural fact about licensing administration that predates this cycle but continues to shape how any newly licensed or newly exempted entity would interact with the regime. Taken together, the cycle's single confirmed development, the SB261 payroll-processing exemption, is a narrow, targeted liberalisation rather than a broader overhaul of Maryland's money-transmission licensing perimeter. It does not alter the principal-office licensing-administration model, nor does it touch licensing requirements for money transmission generally; it removes one specific, named category of activity, payroll processing performed by an agent of the payor, from the scope of activity requiring licensure. #### Outlook Watch for how the Office of the Commissioner of Financial Regulation interprets the boundaries of the SB261 payroll-processing exemption in practice, since the statutory language is confined to agents of the payor providing payroll-processing services and the practical scope of that carve-out (for example, whether it extends to third-party payroll platforms operating under varying commercial structures) was not established this cycle. No further Maryland money-transmission legislative activity was identified this cycle. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Maryland regulates money transmission broadly under the Maryland Money Transmission Act (Financial Institutions Article, Title 12, Subtitle 4), which requires a general money transmitter licence covering domestic and international transmission activity, without a bespoke electronic-money or payment-institution licence class distinct from that general framework. This cycle's material development is SB 261, which exempts agents of the payor providing payroll-processing services from that licensure requirement, effective October 1, 2026. This is a scope contraction relative to a 2024 development in which the Office of Financial Regulation, through adoption of portions of the CSBS Model Money Transmission Modernization Act, had brought payroll processors within the money-transmission definition in the first place; SB 261 partially reverses that 2024 expansion for this specific activity category. This narrowing sits alongside a standing procedural simplification: effective July 1, 2023, Maryland stopped requiring or issuing individual licences for business locations other than a licensee's principal executive office, permitting licensees to conduct business at disclosed additional locations under the umbrella of a single principal-office licence. Together, these two developments describe a licensing regime that has, over recent cycles, moved toward administrative simplification on the branch-location front while simultaneously fine-tuning the substantive scope of who must be licensed at all, illustrated most recently by the payroll-processor carve-out. The general MTL regime remains the sole state-level licensing lever for digital-asset businesses operating in Maryland as well; there is no separate crypto-specific licensing class, and digital-currency exchanges are licensed as money transmitters under the same statute now being scope-tuned by SB 261. The bank-versus-nonbank distinction in Maryland's licensing framework is structural: banks and other depository institutions are generally exempt from money transmitter licensure by virtue of their existing prudential supervision, while nonbank payment institutions and e-money-equivalent businesses, including crypto exchanges, must obtain and maintain the general MTL licence and pass through the state's character-and-fitness review at licensing and renewal. #### Outlook Watch for whether Maryland continues issuing narrow, activity-specific carve-outs to its money transmission statute following the payroll-processor exemption, and whether the October 1, 2026 effective date for SB 261 surfaces any transition friction for agents of the payor currently licensed under the pre-amendment scope. Periodic update · new data 2026-09-08 #### Licensing, Authorisation & Market Access Maryland's licensing and market-access framework moved on five distinct fronts this cycle, spanning both bank and non-bank payment-institution/e-money-institution rails. On the non-bank side, HB 118 amended the Maryland Money Transmission Act to exclude a person designated as an agent of a payor for payroll-processing purposes from the statutory 'money transmitter' definition, effective October 1, 2026; OFR estimates the exemption affects three companies and brings Maryland's treatment of payroll processors into alignment with the approach already taken by peer Model Law states. This is a licensing-scope narrowing in the exemption's favor — it removes a category of non-bank payment activity from the money-transmitter licensing perimeter rather than adding to it. Running in the opposite direction, Maryland repealed an exemption that had allowed persons who acquire or are assigned certain mortgages, mortgage loans, or installment loans to avoid state financial-services licensing requirements altogether. This repeal closes a licensing gap that had been surfaced by cross-filed passive-trust exemption bills in the 2025 session, and it applies to the non-bank financial-services licensing perimeter broadly rather than to payment institutions specifically. The most consequential development for market access is the finalization and expansion of Maryland's virtual-currency-kiosk registration regime. The Office of the Commissioner of Financial Regulation adopted COMAR 09.03.16 on a permanent basis, effective March 30, 2026, requiring each virtual-currency-kiosk operator and each kiosk itself to register with OFR through the Nationwide Multistate Licensing System (NMLS), with registration mandatory from January 1, 2026. Companion legislation, SB 741, effective October 1, 2026, broadens the statutory definition of 'virtual currency kiosk operator' to capture software-based kiosk deployers — not merely physical automated-teller-machine-style kiosks — and removes the regime's prior ATM exclusion outright. This combination substantially widens the population of non-bank payment-institution-adjacent operators now subject to a state registration requirement, on a compressed timeline: registration obligations began taking effect from January 2026, with the broadened scope following in October 2026. On the bank side of the ledger, Maryland reduced the examination fee required to obtain a new commercial-bank charter from $15,000 to $7,000, a direct reduction in the cost of market entry for prospective bank-chartered participants, including those seeking a bank charter to support payment-services activity. This bank-specific cost reduction sits in analytical contrast to the tightening non-bank kiosk-registration regime: Maryland is simultaneously lowering entry cost on the bank-charter pathway while raising the registration and compliance burden on non-bank crypto-kiosk operators, illustrating the bank-PSP versus non-bank-PI/EMI distinction that runs through this module. Each of these five developments carries strong sourcing: the payroll-processor exemption and mortgage/installment-assignee repeal are both confirmed at High confidence from OFR's own 2026 legislative review (Tier 1), the COMAR kiosk-registration finalization is likewise a Tier-1, High-confidence primary-source finding, and the SB 741 scope-broadening and bank-charter fee reduction are each corroborated at Tier 2 by independent legal-industry reporting. For prospective market entrants, the practical read is bifurcated by business model. A payroll-processing agent of a payor now sits outside Maryland's money-transmitter licensing perimeter entirely from October 2026, reducing licensing friction for that narrow category. A virtual-currency-kiosk operator — whether hardware-based or, from October 2026, software-based — faces an expanded and now-permanent registration obligation with no equivalent narrowing. A prospective bank charter applicant faces a lower upfront examination-fee cost than before. And any entity previously relying on the mortgage/installment-loan-assignee exemption to avoid licensing altogether must now assess its licensing exposure under the repealed-exemption baseline for the first time this cycle. #### Outlook The next concrete milestones are the October 1, 2026 effective dates for both HB 118's payroll-processor exemption and SB 741's kiosk-scope broadening. Newly captured software-based kiosk deployers should treat the October 2026 date, not the earlier March 2026 COMAR effective date, as their operative registration deadline. The bank-charter fee reduction has no further scheduled milestone but remains a standing lower-cost entry pathway for new bank charters going forward. Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access Maryland's 2026 legislative session produced three distinct movements in the state's money-transmission and financial-institution licensing perimeter. SB741 (Chapter 417), effective October 1, 2026, expands the definition of virtual currency kiosk operator to capture software-based kiosk operators, removes the prior exclusion for automated teller machines, and clarifies that kiosks may not offer ATM-equivalent services, closing a registration gap for a nonbank cash-in/cash-out channel into digital assets. Separately, a narrower measure excludes payroll processors acting as agent-of-payor, subject to certain standards, from Maryland's money-transmitter definition, aligning Maryland with several other states that already carve out this activity; the Office of Financial Regulation estimates the change affects three companies, a commercially minor exemption relative to the kiosk expansion. A third, corrective measure, SB784, repeals an erroneously enacted all-purchasers exemption from the Mortgage Lender Law and Installment Loan Law, restoring consistency between statute and Office of Financial Regulation guidance without affecting the separate passive-trusts exemption. Read together, the net direction of this cycle's licensing perimeter activity is tightening: the kiosk expansion is a meaningful increase in nonbank registration scope, the payroll-processor exemption is a narrow and commercially minor carve-out, and the mortgage-law repeal is corrective rather than substantive. The bank-versus-nonbank distinction is explicit in two of the three measures: kiosk operators and payroll processors are both nonbank actors whose perimeter status changed this cycle, while no bank-specific licensing movement was evidenced. #### Outlook Watch for the kiosk-oversight expansion's effective date of October 1, 2026, and for whether newly captured software-based kiosk operators come into registration compliance ahead of or in response to enforcement activity. The payroll-processor exemption and mortgage-law correction are unlikely to generate further near-term developments absent litigation or further corrective legislation. **Sources and findings (7)** 1. T3 [https://www.bondexchange.com/maryland-money-transmitter-bond-a-comprehensive-guide/](https://www.bondexchange.com/maryland-money-transmitter-bond-a-comprehensive-guide/) retrieved 2026-07-05 2. T1 [https://www.labor.maryland.gov/finance/industry/moneytran.shtml](https://www.labor.maryland.gov/finance/industry/moneytran.shtml) retrieved 2026-07-05 3. T3 [https://www.jdsupra.com/legalnews/maryland-finalizes-money-transmitter-9745083/](https://www.jdsupra.com/legalnews/maryland-finalizes-money-transmitter-9745083/) retrieved 2026-07-05 4. T1 [https://www.labor.maryland.gov/finance/industry/checkcash.shtml](https://www.labor.maryland.gov/finance/industry/checkcash.shtml) retrieved 2026-07-05 5. T3 [https://www.consumerfinancefintechblog.com/2025/05/maryland-enacts-earned-wage-access-law/](https://www.consumerfinancefintechblog.com/2025/05/maryland-enacts-earned-wage-access-law/) 6. T1 [https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf](https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf) retrieved 2026-07-05 7. T3 [https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/maryland-money-transmitter-license/](https://faisalkhan.com/solutions/licensing/money-transmitter-license-mtl/maryland-money-transmitter-license/) retrieved 2026-07-05 ### W1b Conduct, Safeguarding & Promotions Confirmed confirmed 2026-07-05 Maryland's conduct regime for EWA moves from HB1294 (2025, tipping permitted with disclosure) to SB94 (2026, tipping banned), effective October 1, 2026. Horizon · 2026-10-01 (±quarter) SB94 Earned Wage Access tipping ban in force_in_force_pending · TT3_ Standing sub-brief · as of 5 July 2026 160 words · last cycle 2026-07-05 #### Conduct, Safeguarding & Financial Promotions Maryland's core consumer-fund safeguarding mechanism for money transmitters is a surety bond rather than a trust or segregation model: a minimum $150,000 bond, scaling to $1,000,000 with transmission volume, stands in place of asset segregation. Conduct requirements tightened substantially this cycle. Senate Bill 94, signed April 28, 2026, bans tipping in earned wage access products and mandates overdraft-fee reimbursement, though it does not take effect until October 1, 2026 — HB1294 (2025), which permits disclosed tipping, remains the operative regime until then. Finalized Virtual Currency Kiosk rules under COMAR 09.03.16, effective January 13, 2026, impose disclosure-timing, receipt-content, ATM-style physical-safety, sanctioned-wallet screening, and chief-compliance-officer designation requirements on kiosk operators. #### Outlook The conduct layer is escalating on two tracks: the EWA tipping ban's October 2026 in-force date is the operative milestone to track rather than the April signing date, and the kiosk conduct rules' sanctioned-wallet screening requirement creates a direct operational link to this jurisdiction's AML/CFT posture. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://suretygroup.com/surety-bond/maryland-money-transmitter-bond/](https://suretygroup.com/surety-bond/maryland-money-transmitter-bond/) retrieved 2026-07-05 2. T3 [https://www.consumerfinancialserviceslawmonitor.com/2026/05/maryland-enacts-sweeping-earned-wage-access-reforms-bans-tipping/](https://www.consumerfinancialserviceslawmonitor.com/2026/05/maryland-enacts-sweeping-earned-wage-access-reforms-bans-tipping/) retrieved 2026-07-05 3. T3 [https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks](https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks) retrieved 2026-07-05 4. T3 [https://www.goodwinlaw.com/en/insights/publications/2025/05/alerts-finance-ftec-maryland-enacts-law](https://www.goodwinlaw.com/en/insights/publications/2025/05/alerts-finance-ftec-maryland-enacts-law) retrieved 2026-07-05 5. T1 [https://labor.maryland.gov/finance/advisories/advisory-cryptocurrencyconsumer.pdf](https://labor.maryland.gov/finance/advisories/advisory-cryptocurrencyconsumer.pdf) ### W2 Stablecoins & Digital Money Confirmed confirmed 2026-07-05 Maryland enacted the Maryland Stablecoin Act (SB662/HB1355) on May 12, 2026, effective January 1, 2027, establishing OFR as stablecoin regulator and a state-issuer/nondepository-trust-company route; a Blockchain Task Force reports by Oct 1, 2027. Horizon · 2027-01-01 (±quarter) Maryland Stablecoin Act (SB662/HB1355) in force_in_force_pending · TT3_ Horizon · 2027-10-01 (±quarter) Blockchain and Cryptocurrency Task Force report due_proposed · TT1_ Standing sub-brief · as of 5 July 2026 156 words · last cycle 2026-08-05 #### Stablecoins & Digital Money The Maryland Stablecoin Act (SB662/HB1355), enacted May 12, 2026, establishes a state-issuer and payment-stablecoin-service-provider framework, effective January 1, 2027. OFR is designated the state's stablecoin regulator and will issue GENIUS Act-modeled regulations while standing up internal and external stablecoin committees. Federal Treasury rulemaking under the GENIUS Act requires state regimes seeking "substantially similar" status to match OCC-level reserve-asset and capital standards, meaning Maryland's implementing rules must be calibrated against a federal benchmark whose own rulemaking progression — ANPRM, NPRM, or final rule — is unresolved as of this retrieval date. A Blockchain and Cryptocurrency Task Force, staffed by OFR, must report to the Governor and General Assembly by October 1, 2027. #### Outlook Maryland's early-mover stablecoin posture is High confidence but implementation-dependent: the January 2027 in-force date, the Task Force's October 2027 report, and the still-unresolved federal calibration standard together define the window in which this regime's real market impact will become visible. Periodic update · new data 2026-08-11 #### Stablecoins & Digital Money The Maryland Stablecoin Act (SB662/HB1355) was signed and takes effect January 1, 2027, establishing the Office of Financial Regulation as Maryland's stablecoin regulator. Nondepository trust companies must disclose stablecoin intent in their articles of incorporation and obtain Commissioner authorization before engaging in stablecoin activity, while banks and credit unions must notify the Office of Financial Regulation before seeking federal Permitted Payment Stablecoin Issuer approval, an explicit structural link between the state regime and the federal track rather than two wholly independent supervisory tracks. The safeguarding standard behind the Act is modeled directly on the federal GENIUS Act framework, indicating Maryland's intent to align with, rather than diverge from, the emerging federal baseline even while building its own supervisory capacity ahead of federal finality. This state-level build-out runs concurrently with the kiosk-oversight expansion under SB741, which brings software-based virtual-currency-kiosk operators into registration, giving Maryland a more complete supervisory picture across both stablecoin issuance and a common retail on/off-ramp channel for digital assets within the same legislative cycle. Both bank and nonbank actors are implicated: nondepository trust companies face a new authorization gate, while depository institutions face a new notification requirement layered on top of their existing federal posture. #### Outlook The central near-term question is how Maryland's state-level stablecoin authorization interacts operationally with the federal GENIUS Act Permitted Payment Stablecoin Issuer framework once that framework's final compliance rules are adopted; the Act's January 1, 2027 effective date sits close enough to the federal track's expected timeline that the sequencing of the two approvals is itself a market-access variable for prospective issuers. **Sources and findings (6)** 1. T3 [https://www.jdsupra.com/legalnews/maryland-governor-signs-bill-8307759/](https://www.jdsupra.com/legalnews/maryland-governor-signs-bill-8307759/) retrieved 2026-07-05 2. T1 [https://labor.maryland.gov/finance/fr2026legislativereview.shtml](https://labor.maryland.gov/finance/fr2026legislativereview.shtml) retrieved 2026-07-05 3. T1 [https://www.consumerfinancialserviceslawmonitor.com/2026/04/treasury-proposes-genius-act-principles-for-acceptable-state-stablecoin-regimes/](https://www.consumerfinancialserviceslawmonitor.com/2026/04/treasury-proposes-genius-act-principles-for-acceptable-state-stablecoin-regimes/) retrieved 2026-07-05 4. T3 [https://digitalchamber.org/md-leads-the-way/](https://digitalchamber.org/md-leads-the-way/) retrieved 2026-07-05 5. T1 [https://labor.maryland.gov/finance/fr2026legislativereview.shtml](https://labor.maryland.gov/finance/fr2026legislativereview.shtml) retrieved 2026-07-05 6. T3 [https://www.billtrack50.com/billdetail/1967974](https://www.billtrack50.com/billdetail/1967974) retrieved 2026-07-05 ### W3 Operational Resilience & Critical Infrastructure Confirmed confirmed 2026-07-05 Maryland lacks a dedicated payments-sector operational-resilience statute equivalent to DORA; resilience obligations for payments/financial entities instead flow from the state's general data-breach notification law (PIPA), sector-specific insurance-carrier cybersecurity-event reporting rules, and an OFR-issued Emergency Preparedness Guide for state-chartered depository institutions. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 5 July 2026 176 words · last cycle 2026-07-05 #### Operational Resilience & Critical Infrastructure Maryland has no payments-specific operational-resilience statute equivalent to the EU's DORA. The backstop instead runs through the Personal Information Protection Act, Commercial Law §14-3504, which requires businesses handling Maryland residents' personal data to notify affected individuals no later than 45 days after breach discovery absent a finding that misuse is unlikely. Insurance carriers face a tighter clock: Insurance Article cybersecurity-event reporting rules require notification to the Insurance Commissioner within 3 business days of determining a reportable event has occurred. For state-chartered depositories, OFR's Depository Supervision Unit maintains an Emergency Preparedness Guide, last revised August 2023, as its operational-resilience expectation. A federal layer sits atop all of this: under CIRCIA, Maryland-based critical-infrastructure entities must report substantial cyber incidents to CISA within 72 hours. #### Outlook This module's trajectory is stable rather than escalating: absent a dedicated payments-resilience statute, Maryland's posture will continue to be read as an assembly of general breach law, sector-specific insurance rules, and the federal CIRCIA backstop, a structural gap relative to EU/UK peers that this monitor will keep tracking. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://mgaleg.maryland.gov/mgawebsite/laws/StatuteText?article=gcl§ion=14-3504&enactments=False&archived=False](https://mgaleg.maryland.gov/mgawebsite/laws/StatuteText?article=gcl§ion=14-3504&enactments=False&archived=False) retrieved 2026-07-05 2. T2 [https://www.constangy.com/data-privacy-us-md](https://www.constangy.com/data-privacy-us-md) retrieved 2026-07-05 3. T1 [https://labor.maryland.gov/finance/banks/](https://labor.maryland.gov/finance/banks/) retrieved 2026-07-05 4. T3 [https://www.mwe.com/insights/maryland-joins-growing-ranks-and-passes-its-own-consumer-data-privacy-law/](https://www.mwe.com/insights/maryland-joins-growing-ranks-and-passes-its-own-consumer-data-privacy-law/) retrieved 2026-07-05 5. T3 [https://pivitstrategy.com/maryland-cybersecurity-laws-you-should-know-2026/](https://pivitstrategy.com/maryland-cybersecurity-laws-you-should-know-2026/) retrieved 2026-07-05 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-05 Maryland has no state-specific interchange-fee cap or dedicated card-scheme statute; card acceptance in the state follows Visa/Mastercard network rules (surcharge caps of 3%/4% respectively) and the national interchange landscape, which is being reshaped by the long-running Payment Card Interchange Fee antitrust litigation settlement. Legislative attempts to cap Maryland surcharges at true cost of acceptance failed in 2024. Horizon · 2026-Q2 (±multi_year) MDL 1720 interchange settlement rate-freeze/cap phase-in window_adopted · TT3_ Standing sub-brief · as of 5 July 2026 157 words · last cycle 2026-07-05 #### Scheme & Network Compliance Maryland merchants operate under national card-network surcharge rules rather than a state-specific interchange cap: surcharging is capped at up to 4% (3% for Visa), and the state's 2024 attempt to legislate a true-cost-of-acceptance surcharge cap failed to pass. The more consequential development this cycle is national rather than Maryland-specific: the amended interchange settlement in In re Payment Card Interchange Fee and Merchant Discount Antitrust Litigation (MDL 1720) received court approval in June 2026, following an April 27 hearing, after research had characterized it as still proposed. The settlement caps standard consumer credit interchange at 1.25% for eight years, freezes posted rates for five years, and expands surcharging to 3%, directly affecting Maryland merchants and acquirers as settlement class members. #### Outlook The scheme-compliance trajectory is escalating: Maryland merchants and acquirers should treat the MDL 1720 settlement as adopted law rather than a pending proposal, with the rate-freeze and cap provisions phasing in from mid-2026. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T3 [https://www.getnickel.com/surcharge-laws/maryland](https://www.getnickel.com/surcharge-laws/maryland) retrieved 2026-07-05 2. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/credit-card-surcharge-laws-by-state/) retrieved 2026-07-05 3. T2 [https://www.americanbar.org/groups/antitrust_law/resources/newsletters/in-re-payment-card-interchange-fee-merchant-discount-antitrust-litigation/](https://www.americanbar.org/groups/antitrust_law/resources/newsletters/in-re-payment-card-interchange-fee-merchant-discount-antitrust-litigation/) retrieved 2026-07-05 4. T3 [https://www.payram.com/blog/visa-mastercard-swipe-fee-settlement](https://www.payram.com/blog/visa-mastercard-swipe-fee-settlement) retrieved 2026-07-05 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-05 Maryland's principal payment corridors are inbound/outbound remittance flows tied to its large immigrant population, concentrated in the Baltimore-Washington metro area (notably the Langley Park 'International Corridor'), serviced by licensed money transmitters and remittance agents rather than a dedicated state-run instant-payment rail. Standing sub-brief · as of 5 July 2026 86 words · last cycle 2026-07-05 #### Payment Corridor Dynamics Baltimore-Washington metro remittance flows are concentrated in Langley Park's International Corridor, serviced by licensed money-services-business agents rather than a state-run instant-payment rail. Corridor-volume data remains a genuine gap: the underlying source is thin, low-tier, and partly dated, and this monitor flags emerging-market corridor coverage as an under-indexed vector for Maryland pending better data. #### Outlook This corridor's trajectory is stable and thinly evidenced; the priority for the next cycle is closing the corridor-volume data gap rather than assuming continuity from a single low-tier source. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T4 [https://langley-park-md.b-cdn.net/](https://langley-park-md.b-cdn.net/) retrieved 2026-07-05 2. T4 [https://www.sharemoney.com/us/en/state/maryland](https://www.sharemoney.com/us/en/state/maryland) retrieved 2026-07-05 3. T4 [https://builtin.com/companies/location/na/usa/md/type/fintech-companies](https://builtin.com/companies/location/na/usa/md/type/fintech-companies) retrieved 2026-07-05 ### W6 Industry Structure & Commercial limited signal Probable confirmed 2026-07-05 Maryland's payments-adjacent industry structure is anchored by regional bank M&T Bank, a network of state-chartered banks and credit unions, and a smaller fintech/PSP layer supported by OFR's Innovation Contact office and the state-backed Maryland Community Investment Venture (MCIV) Fund, which pairs fintechs with Maryland state-chartered depository institutions. Standing sub-brief · as of 5 July 2026 84 words · last cycle 2026-08-21 #### Industry Structure & Commercial Dynamics M&T Bank anchors Maryland's regional bank presence in the payments-adjacent landscape, serving more than 3.6 million clients across a nine-jurisdiction footprint. The Maryland Community Investment Venture Fund is the state's central bank-fintech partnership vehicle, granting $25,000-$50,000 to fintechs partnering with state-chartered banks and credit unions for pilots without taking equity. #### Outlook Maryland's industry structure remains stable: incumbent regional banking and a grant-funded fintech-partnership model, rather than a wave of new market entrants, define the state's commercial-dynamics baseline for now. Periodic update · new data 2026-09-08 #### Industry Structure & Commercial Dynamics Maryland's industry-structure signal this cycle is the establishment of a formal, public-private Digital Asset and Blockchain Technology Task Force. Governor Moore signed HB 470/SB 376 into law on May 12, 2026, creating a task force co-led with the Maryland Blockchain Association and the Maryland Tech Council, charged with studying blockchain and cryptocurrency use cases and reviewing peer-state regulatory frameworks, with a reporting obligation to the Governor and General Assembly due by October 2027. This is a structural, state-sponsored industry-coordination mechanism rather than a licensing or enforcement action, and it follows directly on the heels of the same session's virtual-currency-kiosk registration finalization — suggesting a state actively repositioning its institutional apparatus around digital-asset policy rather than addressing crypto issues purely through ad hoc legislation. The task force's public-private structure, with formal participation from the state's principal blockchain-industry trade association and technology trade association, signals an industry-structure dynamic in which Maryland's crypto and blockchain sector has secured a direct institutional voice in shaping the state's forward regulatory agenda — a meaningfully different posture than a purely regulator-driven rulemaking process. Its mandate to study peer-state regulatory frameworks specifically indicates Maryland intends to benchmark its own approach against other US states' treatment of digital-asset businesses, which is itself a commercial-dynamics signal. This development is sourced from a single Tier-3 press release at Probable confidence rather than a primary legislative or regulatory document, a materially lower evidentiary bar than the Tier-1, High-confidence licensing developments captured elsewhere this cycle in the W1a module; readers should weight this task-force item accordingly as a signal of legislative intent and industry-coordination structure rather than as a confirmed operative change to Maryland's regulatory perimeter. No M&A activity, investment round, or specific commercial transaction was identified for Maryland this cycle under this module; the task-force launch is the sole industry-structure-level development, distinct from the discrete commercial event captured separately under Commercial Intelligence & Fintech. The pairing of a legislatively created task force with the same-session kiosk-registration and stablecoin-framework enactments suggests industry-structure evolution in Maryland is currently proceeding on two parallel tracks: near-term binding compliance obligations moving through OFR's rulemaking and licensing apparatus, and a longer-horizon policy-study track moving through the newly created task force. #### Outlook The task force's October 2027 reporting deadline is the key milestone to track; its findings and any resulting legislative recommendations could materially reshape Maryland's digital-asset industry-structure trajectory beyond the current session's kiosk-registration baseline. Given the task force was only just established in May 2026, no interim findings or industry-structure shifts attributable to its work are yet observable this cycle. **Sources and findings (4)** 1. T4 [https://builtin.com/companies/location/baltimore/type/fintech-companies](https://builtin.com/companies/location/baltimore/type/fintech-companies) retrieved 2026-07-05 2. T1 [https://labor.maryland.gov/finance/mciv/](https://labor.maryland.gov/finance/mciv/) retrieved 2026-07-05 3. T1 [https://www.labor.maryland.gov/finance/industry/frfintech.shtml](https://www.labor.maryland.gov/finance/industry/frfintech.shtml) retrieved 2026-07-05 4. T4 [https://www.ellty.com/blog/maryland-investors](https://www.ellty.com/blog/maryland-investors) retrieved 2026-07-05 ### W7 Legal & Litigation Confirmed confirmed 2026-07-05 Maryland's litigation/enforcement track record centers on OFR administrative enforcement (CashCall, Cash-N-Go) and multistate BSA/AML action against Block/Cash App. Standing sub-brief · as of 5 July 2026 133 words · last cycle 2026-07-05 #### Legal & Litigation OFR's enforcement track record anchors this module. The Court of Special Appeals upheld a $5,651,000 penalty against CashCall Inc. for unlicensed "credit services business" activity spanning more than 5,000 Maryland loans priced up to 96% APR. A parallel appellate ruling in the Matter of Cash-N-Go, Inc. upheld Commissioner penalties and restitution against a licensed check-casher offering unlicensed loans disguised as title pawns, confirming that the Excessive Fines Clause does not bar the Commissioner's penalty and restitution authority. OFR also joined a multistate $80 million BSA/AML enforcement action against Block, Inc./Cash App, with Maryland's allocated share approximately $1.6 million. #### Outlook This module's trajectory is escalating and Confirmed in confidence: OFR's willingness to pursue unlicensed-lending precedent and coordinate multistate BSA/AML enforcement signals continued state-level appetite for payments-adjacent enforcement independent of federal action. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://caselaw.findlaw.com/court/md-court-of-special-appeals/1716706.html](https://caselaw.findlaw.com/court/md-court-of-special-appeals/1716706.html) retrieved 2026-07-05 2. T1 [https://www.mdcourts.gov/data/opinions/cosa/2022/1012s21.pdf](https://www.mdcourts.gov/data/opinions/cosa/2022/1012s21.pdf) retrieved 2026-07-05 3. T1 [https://labor.maryland.gov/whatsnews/ofrjoins80menforcementactionagainstblockinccashapp.shtml](https://labor.maryland.gov/whatsnews/ofrjoins80menforcementactionagainstblockinccashapp.shtml) retrieved 2026-07-05 4. T1 [https://mgaleg.maryland.gov/mgawebsite/laws/StatuteText?article=gcl§ion=12-514](https://mgaleg.maryland.gov/mgawebsite/laws/StatuteText?article=gcl§ion=12-514) ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-05 Maryland has no bespoke merchant-acquiring statute; acquiring risk practice follows the card networks' national rulebook (Honor All Cards, surcharge caps) as recently amended by the pending national interchange antitrust settlement, and the state's failed 2024 surcharge-cap bills leave Maryland merchants subject to network-set surcharge limits rather than a state-specific cost-of-acceptance cap. Standing sub-brief · as of 5 July 2026 99 words · last cycle 2026-07-05 #### Merchant Acquiring & Risk The amended national interchange settlement introduces a modified Honor All Cards regime, creating three card tiers — standard consumer, premium consumer, and commercial — under which merchants may decline higher-cost tiers while still honoring all cards within an accepted tier. This reshapes acquiring risk practice for Maryland merchants and acquirers, who are class members under the settlement approved in June 2026. #### Outlook The acquiring-risk trajectory is escalating: merchants and acquirers should begin adapting card-acceptance policy to the modified Honor All Cards framework now that court approval has removed the prior uncertainty over the settlement's status. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T2 [https://www.americanbar.org/groups/antitrust_law/resources/newsletters/in-re-payment-card-interchange-fee-merchant-discount-antitrust-litigation/](https://www.americanbar.org/groups/antitrust_law/resources/newsletters/in-re-payment-card-interchange-fee-merchant-discount-antitrust-litigation/) retrieved 2026-07-05 2. T4 [https://www.getflexpoint.com/credit-card-surcharging-us-states/maryland](https://www.getflexpoint.com/credit-card-surcharging-us-states/maryland) retrieved 2026-07-05 3. T3 [https://merchantcostconsulting.com/lower-credit-card-processing-fees/maryland-surcharge-laws/](https://merchantcostconsulting.com/lower-credit-card-processing-fees/maryland-surcharge-laws/) retrieved 2026-07-05 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-05 Maryland's product-innovation posture is built on the MCIV Fund's fintech-bank pilot pairing model, a new Blockchain and Cryptocurrency Task Force, UCC Article 12 modernisation for controllable electronic records, and an emergent state Bitcoin Reserve Fund, positioning the state as actively courting digital-asset and fintech innovation while channeling it through regulated bank partnerships. Horizon · 2027-Q1 (±half_year) SB154 (UCC Art. 12 controllable electronic records) expected resubmission_proposed · TT4_ Standing sub-brief · as of 5 July 2026 144 words · last cycle 2026-08-05 #### Product Innovation & Market Development The Maryland Community Investment Venture Fund extended its 2025 fintech-pilot grant-proposal deadline to January 31, 2026, continuing the state's central bank-fintech pilot channel. Separately, legislation establishes a State Bitcoin Reserve Fund, authorizing the state treasurer to invest gambling-enforcement proceeds in Bitcoin as a reserve asset, adjacent to but distinct from core payments-instrument scope. A bill to modernize Maryland's commercial code to recognize controllable electronic records under UCC Article 12, SB154, appears not to have passed the 2026 session despite earlier framing as enacted law; a state blockchain trade association indicates it is slated for resubmission in the January 2027 session. #### Outlook Product innovation here is escalating but unevenly verified: the MCIV pilot channel and Bitcoin Reserve Fund are confirmed developments, while SB154's enactment status should be treated as pending rather than settled until confirmed against the primary legislative record. Periodic update · new data 2026-08-11 #### Product Innovation & Market Development SB759, the Digital Assets and Digital Asset Staking Act, also referenced as the Maryland Financial Innovation Act of 2026, bars state and local restrictions on Maryland residents' self-custody of digital assets, node operation, and blockchain software development, and clarifies that staking-as-a-service is not a securities offering under the Maryland Securities Act. This is a product-access regulatory clarification rather than a licensing or prudential measure: it removes a specific legal uncertainty, whether offering staking as a service triggers state securities registration, that has constrained product design for digital-asset firms operating in or serving Maryland residents. The finding rests on a single source this cycle and is rendered at assessed rather than high confidence. The clarification sits alongside Maryland's stablecoin and kiosk measures as part of a broader 2026 legislative pattern addressing digital-asset market structure from multiple angles simultaneously, though SB759's self-custody and staking provisions are analytically distinct from the licensing and stablecoin-regulator measures: SB759 protects certain digital-asset activities from state-level restriction rather than creating new registration or authorization obligations. #### Outlook Watch for whether other states adopt comparable staking-as-a-service securities-law clarifications, and for whether Maryland's self-custody and node-operation protections are tested against any future state-level restriction proposal. **Sources and findings (4)** 1. T1 [https://labor.maryland.gov/finance/mciv/](https://labor.maryland.gov/finance/mciv/) retrieved 2026-07-05 2. T3 [https://digitalchamber.org/md-leads-the-way/](https://digitalchamber.org/md-leads-the-way/) retrieved 2026-07-05 3. T3 [https://marylandblockchainassociation.org/resources/md-legislation/](https://marylandblockchainassociation.org/resources/md-legislation/) retrieved 2026-07-05 4. T3 [https://digitalchamber.org/md-leads-the-way/](https://digitalchamber.org/md-leads-the-way/) retrieved 2026-07-05 ### W10 Consumer Protection & APP Fraud Confirmed confirmed 2026-07-05 Maryland's 2025-26 legislative program substantially expanded payments-adjacent consumer protection, closing regulatory loopholes for app-based earned-wage-access 'payday loans,' expanding the Access to Banking Act to reach underbanked consumers directly, and building fraud-refund and disclosure mechanics into the new virtual currency kiosk regime. The Attorney General's Consumer Protection Division and OFR share enforcement. Standing sub-brief · as of 5 July 2026 135 words · last cycle 2026-07-05 #### Consumer Protection & APP Fraud SB94, signed April 28, 2026 and in force October 1, 2026, closes app-based payday-loan-style loopholes in earned wage access products; a 2024 Market Inquiry had found Maryland consumers paid more than $35 million in fees on 5.5 million EWA transactions between 2019 and 2024, with dark-pattern tip pricing averaging more than $280 per user. The 2023 Access to Banking Act was expanded in 2026 via SB43/HB259 to create a collaborative model and Maryland Opportunity Accounts, channeling fee credits to banks and credit unions that bring unbanked and underbanked residents into the formal financial system. #### Outlook Consumer protection is the most escalating tracker in this cycle's Maryland output: the EWA fee-and-tipping evidence base is strong, but the reform's practical effect will not be testable until the October 2026 in-force date passes. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T1 [https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml](https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml) retrieved 2026-07-05 2. T1 [https://www.labor.maryland.gov/finance/banks/access-to-banking.shtml](https://www.labor.maryland.gov/finance/banks/access-to-banking.shtml) retrieved 2026-07-05 3. T1 [https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml](https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml) retrieved 2026-07-05 4. T3 [https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks](https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks) retrieved 2026-07-05 5. T1 [https://oag.maryland.gov/i-need-to/Pages/Guidelines-for-Businesses-to-Comply-with-the-Maryland-Personal-Information-Protection-Act.aspx](https://oag.maryland.gov/i-need-to/Pages/Guidelines-for-Businesses-to-Comply-with-the-Maryland-Personal-Information-Protection-Act.aspx) retrieved 2026-07-05 ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/united-states-maryland/#sec-dom-D7) Probable confirmed 2026-07-05 Maryland's AML/CFT posture for payments follows the federal Bank Secrecy Act framework administered by FinCEN, with Maryland-licensed money transmitters registering as MSBs and OFR participating in multistate AML enforcement. A direct proprietary Sentinel.gi feed connection was not accessible within this research pass; the findings below are drawn from public-record BSA/AML enforcement and regulatory statements standing in as the payments-context AML posture pending Sentinel.gi feed integration. Standing sub-brief · as of 5 July 2026 127 words · last cycle 2026-07-05 #### AML/CFT & Financial Crime This module is sourced from the Sentinel.gi feed; direct proprietary access was unavailable this pass, so the findings below are carried from public-record BSA/AML sources standing in pending feed integration, with original illicit-finance analysis routed to FIM rather than analysed here. Multistate regulators, including Maryland's OFR, found Block, Inc./Cash App non-compliant with BSA/AML due-diligence requirements, resulting in an $80 million settlement. Separately, every money-services business, including Maryland-licensed money transmitters, must register with FinCEN and maintain a written AML compliance program under the Bank Secrecy Act. #### Outlook This module's trajectory is stable: the federal BSA/MSB backbone applies uniformly, and the standout signal remains the Block/Cash App multistate settlement, which this monitor carries as Sentinel-fed provenance pending direct feed integration rather than original AML analysis. no periodic updates on record for this sub-brief ** Sources and findings (7)** 1. T1 sentinel.https://www.irs.gov/businesses/small-businesses-self-employed/money-services-business-msb-information-center 2. T? FIM (sentinel.gi) per-JID baseline profile — United States — Maryland — Maryland operates under the federal Bank Secrecy Act/FinCEN AML/CFT architecture (BSA, CTA, OFAC sanctions) with no independent state AML statute; the state layer consists of money-transmitter licensing under the Maryland Financial Institutions Article administered by the Office of the Commissioner of Financial Regulation. Federal 2025 deregulatory moves (CTA domestic BOI exemption) materially thinned the transparency layer applicable to Maryland-registered entities. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness 4. T1 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: OFAC delisting 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence 6. T1 FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: OFAC — U.S. persons and financial institutions nationwide, including Maryland-domiciled entities 7. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-05 Maryland has no distinct state-level correspondent-banking or settlement-access statute; correspondent relationships and settlement-system membership for Maryland-chartered and Maryland-domiciled institutions are governed by the federal framework (Federal Reserve, OCC, FDIC) rather than state law, with the state's role limited to chartering and supervising depository/trust institutions that then access federal settlement rails. Standing sub-brief · as of 5 July 2026 135 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Maryland has no distinct correspondent-banking statute; settlement access instead flows through OFR's Depository Supervision Unit, which charters and supervises all Maryland-chartered banks, credit unions, and trust companies as the gateway to federal Fed/OCC/FDIC settlement-system access. This module's bank-versus-nonbank asymmetry is the analytical spine here: chartered depositories hold direct settlement access that non-bank licensees do not. The 2026 amendments to the nondepository trust-company charter, carried in HB1355, authorize the Commissioner to reduce capital-stock requirements in certain circumstances, a provision relevant to reserve-custody and settlement arrangements for a prospective stablecoin issuer. #### Outlook This module's trajectory is stable in structure but consequential in direction: the new trust-company capital flexibility bridges licensing, stablecoin, and correspondent-access questions, and it is worth tracking how OFR calibrates reserve-custody expectations as the Stablecoin Act's 2027 in-force date approaches. no periodic updates on record for this sub-brief ** Sources and findings (3)** 1. T1 [https://labor.maryland.gov/finance/banks/](https://labor.maryland.gov/finance/banks/) retrieved 2026-07-05 2. T1 [https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf](https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf) retrieved 2026-07-05 3. T4 [https://builtin.com/companies/location/baltimore/type/fintech-companies](https://builtin.com/companies/location/baltimore/type/fintech-companies) retrieved 2026-07-05 ### W13 Commercial Intelligence (M&A, Investment & Product) limited signal Probable confirmed 2026-07-05 Maryland established a Digital Asset and Blockchain Technology Task Force to study blockchain/cryptocurrency policy, with a report due to the Governor and General Assembly by October 1, 2027; OFR will staff and facilitate the task force. Standing sub-brief · as of 5 July 2026 152 words · last cycle 2026-08-21 #### Commercial Intelligence (M&A, Investment & Product) The Maryland Community Investment Venture Fund is this cycle's only clean W13 commercial event: an ongoing investment program pairing fintechs with Maryland state-chartered banks and credit unions for pilot funding, with the 2025 proposal deadline extended to January 31, 2026. Individual award amounts and recipients are not publicly disclosed at the program level. Other candidate items surfaced in research this cycle — the Stablecoin Act signing, EWA reform signing, kiosk-rule finalization, and the Block/Cash App settlement — are regulatory and enforcement events rather than M&A, investment, or product-launch events under this module's schema, and have been reclassified to W1b, W2, W7, and W10 rather than force-fit into W13. #### Outlook This module's trailing content is thin: trailing-twelve-month activity in Maryland is dominated by regulatory and enforcement developments rather than discrete commercial transactions, and the next cycle should watch for whether the MCIV cohort produces individually disclosed deals. Periodic update · new data 2026-09-08 #### Commercial Intelligence & Fintech The sole commercial-intelligence event identified for Maryland this cycle is the Maryland Blockchain Association's 'Maryland BlockchAIn Bootcamp and Workforce Expo,' held July 13-17, 2026 at Capitol Technology University. This is an industry-coalition workforce-development event rather than a disclosed commercial transaction such as an M&A deal or funding round; per this module's scope, it is rendered as a discrete commercial event rather than folded into the structural industry-analysis reading captured separately under Industry Structure & Commercial Dynamics. The event followed directly on Maryland's broader 2026 digital-asset legislative package — including the virtual-currency-kiosk registration finalization and the Stablecoin Act — and reflects industry-side mobilization around workforce development in direct response to that legislative activity. No M&A transaction, investment or funding round, or specific product-launch event was identified for Maryland this cycle; this module's content is limited to the single workforce-development event above, sourced at Tier 3 and Assessed confidence, with the amount/value dimension not applicable to this type of event. #### Outlook Watch for whether the Maryland Blockchain Association or Maryland Tech Council announce further workforce-development or industry-coordination events tied to the new Digital Asset and Blockchain Technology Task Force's ongoing work through its October 2027 reporting deadline. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Commercial Intelligence & Fintech The Maryland General Assembly created a Digital Asset and Blockchain Technology Task Force this cycle, to be staffed and facilitated by the Office of Financial Regulation, with a policy report due to the Governor and General Assembly by October 1, 2027. This is a policy-body-formation event rather than a licensing, enforcement, or product development, distinct from the substantive stablecoin, kiosk, and staking measures enacted in the same session, and it signals that Maryland intends to treat this cycle's legislative package as a starting point for further blockchain and cryptocurrency policy work rather than a completed framework. #### Outlook Watch for the Task Force's composition and initial work plan, and for whether its October 2027 report addresses the practical interaction between the stablecoin regime, kiosk registration, and the staking-as-a-service clarification as a single coordinated policy question. **Sources and findings (5)** 1. T3 [https://www.jdsupra.com/legalnews/maryland-governor-signs-bill-8307759/](https://www.jdsupra.com/legalnews/maryland-governor-signs-bill-8307759/) retrieved 2026-07-05 2. T1 [https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml](https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml) retrieved 2026-07-05 3. T3 [https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks](https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks) retrieved 2026-07-05 4. T1 [https://labor.maryland.gov/whatsnews/ofrjoins80menforcementactionagainstblockinccashapp.shtml](https://labor.maryland.gov/whatsnews/ofrjoins80menforcementactionagainstblockinccashapp.shtml) retrieved 2026-07-05 5. T1 [https://labor.maryland.gov/finance/mciv/](https://labor.maryland.gov/finance/mciv/) retrieved 2026-07-05 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for United States – Maryland| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{"legal_accessibility": {"per_product": {"account_to_account": "regulated", "cards": "regulated", "stablecoin": "emerging-regime"}}}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 1 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 65 finding(s), 154 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).