Maryland (MD)
Money transmission and virtual currency licensing planning data for Maryland.
Population weight (planning): 1.81% · Back to matrix · Launch map
How to read this page: confirmed cells are checked against a primary regulatory source and dated. Under review marks a cell where primary sources conflict or a figure awaits confirmation.
MTL required
Yes. Maryland's own definition of money transmission reaches other value that substitutes for currency, and the Commissioner's advisory applies this to virtual currency, so both the fiat ramp and the crypto exchange leg of this scenario are covered by one licence.
Verified 2026-07-16. Source
Fiat treatment
Money transmission means selling or issuing payment instruments or prepaid access, or receiving currency, funds or other value that substitutes for currency and transferring it to another person or location, under Md. Code Ann., Financial Institutions section 12-401(p).
Verified 2026-07-16. Source
Virtual currency treatment
Included in the statute. The money transmission definition itself captures other value that substitutes for currency (FI section 12-401(p)), which the Commissioner's industry advisory applies to virtual currency. A separate COMAR 09.03.16 kiosk regime, finalised effective 30 March 2026, adds registration duties for kiosk operators specifically.
Verified 2026-07-16. Source
Regulator
Office of the Commissioner of Financial Regulation (OCFR), Maryland Department of Labor.
Verified 2026-07-16. Source
NMLS / portal
Money Transmitter Licence, Maryland Office of the Commissioner of Financial Regulation, applied for and renewed through NMLS.
Verified 2026-07-16. Source
MTMA adoption
full per the CSBS tracker, adopted through COMAR 09.03.14 regulations effective 11 December 2023; the underlying statute is not Model Act text, so practitioner analyses vary.
Verified 2026-07-16. Source
Launch posture
amber: Virtual currency is squarely inside the statutory definition and the bond formula is transparent, but Maryland has not adopted the CSBS Model Act text and carries.
Verified 2026-07-16. Source
Net worth / capital (locked)
Net worth / capital is included with access.Permissible investments (locked)
Permissible investments is included with access.Exam / audit timeline (locked)
Exam / audit timeline is included with access.Practitioner notes (locked)
Practitioner notes is included with access.Under the planning scenario
LicenceMap's bond and net worth figures use one scenario throughout: a virtual currency exchange with a fiat on and off ramp, $50m in annual US transmission volume, $2m in average daily outstanding liability, and a single principal office.
Surety bond: Surety bond is included with access.
Net worth / capital: Net worth / capital is included with access.