On January 13, the Maryland Office of Financial Regulation finalized regulations implementing Maryland's virtual currency kiosk statute. The rules establish a detailed framework governing the registration and operation of virtual currency kiosk operators and individual kiosks across the state, building on statutory requirements that apply beginning January 1, 2026.
The regulations convert the statute's registration mandate into prescriptive operational requirements. In addition to outlining registration mechanics, the framework places significant emphasis on consumer protection measures intended to address fraud risks associated with kiosk-based virtual currency transactions.
The finalized rules include several core components:
- Operator and kiosk registration. Operators must register through NMLS and pay a $2,000 registration fee, while each individual kiosk must be separately registered with a $200 fee. The rules distinguish between fixed-location and mobile kiosks and restrict operation to approved locations or geographic areas.
- Interaction with money transmission requirements. Registration as a kiosk operator does not exempt an entity from money transmission licensing if a kiosk is capable of facilitating money transmission. Conversely, holding a money transmission license does not eliminate the kiosk registration obligation.
- Fraud-related fee refunds. The rules establish a structured process allowing users to request refunds of fees associated with allegedly fraudulent transactions, including defined timelines, investigation standards, and limits on permissible grounds for denial.
- Fraud prevention and compliance controls. Operators must implement wallet-use restrictions, screen for high-risk or sanctioned wallets using blockchain analytics providers, monitor transactions on a risk-based basis, and designate a chief compliance officer.
- Disclosures, receipts, and physical safeguards. The framework imposes minimum on-screen disclosure timing, extensive receipt content requirements, ATM-like lighting and safety standards, and signage directing consumers to the Commissioner for complaints and registration verification.
- Annual reporting. Operators must submit kiosk-level annual reports through NMLS detailing transaction volumes, fraud notices, refunds, and fee activity.
Putting It Into Practice: Maryland's finalized kiosk rules reflect a broader state-level trend toward treating virtual currency kiosks more like traditional money services infrastructure (previously discussed here). Companies operating across multiple states should also monitor whether other jurisdictions adopt similar kiosk-specific regulatory models in 2026.
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