United States — Maine (US-ME)

Updated 5 Jul 2026Schema world-payments-v1Baseline wpm-2026-07-08

Lead Signal

Maine's 2025 virtual-currency-kiosk law, paired with a 2026 consent agreement against kiosk operator Bitcoin Depot, has produced one of the most comprehensive US state-level consumer-protection regimes governing crypto ATMs. The kiosk law caps operator fees at the greater of $5 or 3% of transaction value, imposes a $1,000 daily transaction limit, and requires records to be retained for at least three years. It also entitles kiosk customers to a full refund, including fees, for fraud-induced transactions made within 90 days of a customer's first use of a kiosk, provided the fraud is reported to law enforcement within one year — a response introduced after the FBI reported $31 million in 2024 Maine crypto-fraud losses. Layered onto this framework, the Bitcoin Depot consent agreement — negotiated by the Bureau of Consumer Credit Protection and the Office of the Attorney General — recovered $1.9 million for defrauded Maine consumers and requires Bitcoin Depot to operate as a licensed money transmitter, to comply with an unhosted-wallet-control provision mandating that consumers own and control their virtual wallets, and to maintain a Gramm-Leach-Bliley-Act-consistent information-security program mandated for kiosk operators under a 2025 amendment to Title 32 Chapter 80. Together, these instruments layer transaction-level consumer protection onto Maine's existing money-transmitter licensing backbone.

Outlook

The Visa/Mastercard interchange-fee settlement's final court approval is expected in the first quarter of 2027, though the timeline carries a half-year uncertainty band and the settlement will not alter Maine's own surcharge ban. Corient's application to acquire H.M. Payson & Co.'s trust assets remains before Maine regulators, and the Federal Reserve's proposal to permit intermediaries within FedNow transfers remains open for public comment with no confirmed final-rule date. Maine's consumer-protection stack around digital-money and kiosk activity is likely to remain the state's most active payments-regulatory vector, even as its core MMTMA licensing framework and card-surcharge rule stay stable.

Confidence
Confirmed
Forward deadlines
1

Other Developments

Maine's core non-bank payments licensing regime continues to run through the Money Transmission Modernization Act (MMTMA), 32 M.R.S. Chapter 79-A, effective August 9, 2024, which replaced the prior Money Transmitters Act and is administered by the Bureau of Consumer Credit Protection via NMLS. An administrative modernisation completed this cycle: the Bureau migrated its surety-bond process to Electronic Surety Bonds via NMLS beginning September 1, 2025, with all existing licensees required to convert by January 31, 2026 — a deadline that has now passed. The statute continues to exempt supervised financial organizations, i.e., banks, and payment-system operators processing between exempted persons or licensees from money-transmission licensure, preserving Maine's dual-track regime in which non-bank payment institutions are licensed by the Bureau of Consumer Credit Protection while bank-chartered PSPs are supervised separately by the Bureau of Financial Institutions.

On the conduct side, Maine sellers and merchants remain prohibited from imposing credit or debit card surcharges under 9-A M.R.S. §8-509, subject only to a narrow government-entity carve-out for taxes, fines, and fees — one of just four US jurisdictions, alongside Connecticut, Massachusetts, and Puerto Rico, maintaining a full surcharge ban as of 2026. That standing prohibition sits apart from a separate national development: the revised Visa/Mastercard interchange-fee antitrust settlement received preliminary federal court approval in June 2026, though final approval is not expected until late 2026 or early 2027, and the settlement carries no Maine-specific provisions.

Maine's community-banking and trust sector continued to consolidate. Gorham Savings Bank and Maine Community Bancorp completed their merger effective January 1, 2026, forming an enlarged Maine Community Bank that is now the largest mutual savings bank operating exclusively in Maine, with more than 370 employees. Separately, Corient Partners, LLC filed on April 3, 2026 to establish Corient Maine Trust Company, LP, and on June 3, 2026 applied to acquire substantially all trust assets of H.M. Payson & Co., with regulatory approval still pending.

On instant payments, a cohort of Maine state-chartered banks — Auburn Savings, Bangor Savings, First National Bank Damariscotta, Franklin Savings, and Maine Community Bank — are live on the Federal Reserve's FedNow Service. The Federal Reserve Board has also proposed, in an April 2026 public-comment release, to allow US banks and credit unions to use intermediaries within FedNow transfers, a step that would extend the domestic correspondent-banking model to the international leg of cross-border payments. Smaller Maine institutions already depend on correspondent structures for rail access: EasCorp, a corporate credit union correspondent, settles instant payments via a pooled joint account at the Federal Reserve Bank of New York on behalf of member credit unions, providing FedNow, RTP, ACH, and wire access without direct Fed master-account connectivity.

On enforcement, the Bureau of Consumer Credit Protection's consent-order practice against Bitcoin Depot sits alongside the Maine Attorney General's standing authority under the Maine Unfair Trade Practices Act to investigate and sue over unfair or deceptive payment practices, with consumers retaining a private right of action including recovery of attorney's fees. Separately, Maine's check cashers and cash-dispensing machine operators remain subject to registration and fee caps under Title 32 Chapter 80 — 5% of face value, or 6% without identification, with lower caps for government-benefit payment instruments — administered distinctly from full money-transmitter licensure. Maine residents also remain protected by the Notice of Risk to Personal Data Act, which requires 30-day breach notification to affected residents, nationwide credit-reporting-agency notification where more than 1,000 persons are affected, and notification to state regulators.

Cross-Monitor Connections

The Bitcoin Depot enforcement action, and the underlying crypto-kiosk fraud it addresses, involves scam proceeds that moved through unhosted wallets — an illicit-finance and fraud-proceeds dimension that sits beyond this monitor's consumer-protection scope and has been flagged to the Financial Illicit-finance Monitor for its own analysis of the wallet and proceeds pathway. On the AML/CFT side, Maine's Bureau of Financial Institutions conducts BSA/AML examinations of state-chartered institutions alongside safety-and-soundness and IT reviews, and MMTMA licensees separately cross-reference federal Bank Secrecy Act obligations; the Sentinel.gi payments-context feed that ordinarily supplies this monitor's illicit-finance framing was not accessible this cycle, so this remains standing statutory scaffolding rather than original analysis.

View as
Standing baseline position per module · click a card to expand its full sub-brief

Domains

14 regulatory modules · click to expand the full sub-brief
W1a

Licensing, Authorisation & Market Access

Confirmed

Maine regulates money transmission (including virtual-currency business activity) under the MMTMA, 32 M.R.S. Chapter 79-A, enacted 2024. BCCP is the licensing/supervisory authority via NMLS, with a Sept 2025 shift to Electronic Surety Bonds. Bank-chartered PSPs are supervised separately by the Bureau of Financial Institutions.

W1b

Conduct, Safeguarding & Promotions

Confirmed

Safeguarding runs through MMTMA's surety-bond/permissible-investment regime, layered with an outright card-surcharge ban and new 2025 kiosk disclosure, infosec, and unhosted-wallet-control obligations.

W2

Stablecoins & Digital Money

Confirmed

Maine has no dedicated stablecoin-issuer statute; digital-money regulation runs through MMTMA's virtual-currency-business-activity licensing limb and the 2025 kiosk law (transaction limits, fee caps, fraud refunds).

W3

Operational Resilience & Critical Infra

Assessed

Maine has no DORA-equivalent operational-resilience/critical-third-party statute; resilience runs through generic GLBA-consistent infosec rules and BFI's standard IT/BSA examination cycle.

W4

Scheme & Network Compliance

Assessed

Maine's principal scheme/network rule is its outright surcharge ban, one of only a handful of full US state bans; no bespoke interchange regulation exists.

W5

Payment Corridor Dynamics

Assessed

Maine's principal payments-corridor exposure is its 611-mile Canada border; no Maine-specific cross-border payments instrument exists beyond standard MTO licensing.

+ 8 more domains — W6 Industry Structure & Commercial, W7 Legal & Litigation, W8 Merchant Acquiring & Risk, W9 Product Innovation & Market Development, W10 Consumer Protection & APP Fraud, W11 AML/CFT & Financial Crime, W12 Correspondent Banking, Settlement & Access, W13 Commercial Intelligence (M&A, Investment & Product).
Full per-domain detail — all 14 modules

W1aConfirmedLicensing, Authorisation & Market Access

7 claims

Maine regulates money transmission (including virtual-currency business activity) under the MMTMA, 32 M.R.S. Chapter 79-A, enacted 2024. BCCP is the licensing/supervisory authority via NMLS, with a Sept 2025 shift to Electronic Surety Bonds. Bank-chartered PSPs are supervised separately by the Bureau of Financial Institutions.

No periodic updates yet · baseline brief is current.

W1aLicensing, Authorisation & Market AccessConfirmed
Maine regulates money transmission (including virtual-currency business activity) under the MMTMA, 32 M.R.S. Chapter 79-A, enacted 2024. BCCP is the licensing/supervisory authority via NMLS, with a Sept 2025 shift to Electronic Surety Bonds. Bank-chartered PSPs are supervised separately by the Bureau of Financial Institutions.
all · compliance · analyst · board
Evidence 7 claims ›

W1bConfirmedConduct, Safeguarding & Promotions

5 claims

Safeguarding runs through MMTMA's surety-bond/permissible-investment regime, layered with an outright card-surcharge ban and new 2025 kiosk disclosure, infosec, and unhosted-wallet-control obligations.

No periodic updates yet · baseline brief is current.

W1bConduct, Safeguarding & PromotionsConfirmed
Safeguarding runs through MMTMA's surety-bond/permissible-investment regime, layered with an outright card-surcharge ban and new 2025 kiosk disclosure, infosec, and unhosted-wallet-control obligations.
all · compliance · analyst · board
Evidence 5 claims ›

W2ConfirmedStablecoins & Digital Money

5 claims

Maine has no dedicated stablecoin-issuer statute; digital-money regulation runs through MMTMA's virtual-currency-business-activity licensing limb and the 2025 kiosk law (transaction limits, fee caps, fraud refunds).

No periodic updates yet · baseline brief is current.

W2Stablecoins & Digital MoneyConfirmed
Maine has no dedicated stablecoin-issuer statute; digital-money regulation runs through MMTMA's virtual-currency-business-activity licensing limb and the 2025 kiosk law (transaction limits, fee caps, fraud refunds).
all · compliance · analyst · board
Evidence 5 claims ›

W3AssessedOperational Resilience & Critical Infra

2 claims

Maine has no DORA-equivalent operational-resilience/critical-third-party statute; resilience runs through generic GLBA-consistent infosec rules and BFI's standard IT/BSA examination cycle.

No periodic updates yet · baseline brief is current.

W3Operational Resilience & Critical InfraAssessed
Maine has no DORA-equivalent operational-resilience/critical-third-party statute; resilience runs through generic GLBA-consistent infosec rules and BFI's standard IT/BSA examination cycle.
all · compliance · analyst · board
Evidence 2 claims ›

W4AssessedScheme & Network Compliance

2 claims

Maine's principal scheme/network rule is its outright surcharge ban, one of only a handful of full US state bans; no bespoke interchange regulation exists.

No periodic updates yet · baseline brief is current.

W4Scheme & Network ComplianceAssessed
Maine's principal scheme/network rule is its outright surcharge ban, one of only a handful of full US state bans; no bespoke interchange regulation exists.
all · compliance · analyst · board
Evidence 2 claims ›

W5AssessedPayment Corridor Dynamics

2 claims

Maine's principal payments-corridor exposure is its 611-mile Canada border; no Maine-specific cross-border payments instrument exists beyond standard MTO licensing.

No periodic updates yet · baseline brief is current.

W5Payment Corridor DynamicsAssessed
Maine's principal payments-corridor exposure is its 611-mile Canada border; no Maine-specific cross-border payments instrument exists beyond standard MTO licensing.
all · compliance · analyst · board
Evidence 2 claims ›

W6HighIndustry Structure & Commercial

4 claims

Maine's payments-adjacent financial sector is dominated by community/mutual savings banks and credit unions, consolidating via the Gorham Savings/Maine Community Bancorp merger and Corient's new trust-company formation/H.M. Payson acquisition.

No periodic updates yet · baseline brief is current.

W6Industry Structure & CommercialHigh
Maine's payments-adjacent financial sector is dominated by community/mutual savings banks and credit unions, consolidating via the Gorham Savings/Maine Community Bancorp merger and Corient's new trust-company formation/H.M. Payson acquisition.
all · compliance · analyst · board
Evidence 4 claims ›

W7ConfirmedLegal & Litigation

4 claims

Maine payments litigation/enforcement centers on BCCP consent-order practice against unlicensed/non-compliant transmitters and processors, backstopped by the Attorney General's UTPA authority.

No periodic updates yet · baseline brief is current.

W7Legal & LitigationConfirmed
Maine payments litigation/enforcement centers on BCCP consent-order practice against unlicensed/non-compliant transmitters and processors, backstopped by the Attorney General's UTPA authority.
all · compliance · analyst · board
Evidence 4 claims ›

W8HighMerchant Acquiring & Risk

3 claims

Merchant acquiring economics are directly shaped by the card-surcharge ban; check-cashing/cash-dispensing registrants operate under separate fee-capped registration.

No periodic updates yet · baseline brief is current.

W8Merchant Acquiring & RiskHigh
Merchant acquiring economics are directly shaped by the card-surcharge ban; check-cashing/cash-dispensing registrants operate under separate fee-capped registration.
all · compliance · analyst · board
Evidence 3 claims ›

W9ConfirmedProduct Innovation & Market Development

4 claims

Instant-payments adoption (FedNow) is the leading product-innovation vector in Maine; the 2025 kiosk law is a fast-turnaround regulatory response to a new product category.

No periodic updates yet · baseline brief is current.

W9Product Innovation & Market DevelopmentConfirmed
Instant-payments adoption (FedNow) is the leading product-innovation vector in Maine; the 2025 kiosk law is a fast-turnaround regulatory response to a new product category.
all · compliance · analyst · board
Evidence 4 claims ›

W10ConfirmedConsumer Protection & APP Fraud

6 claims

Maine has built a comprehensive state-level consumer-protection stack anchored by the kiosk fraud-refund law, the Bitcoin Depot redress program, the breach-notification regime, and UTPA's private right of action.

No periodic updates yet · baseline brief is current.

W10Consumer Protection & APP FraudConfirmed
Maine has built a comprehensive state-level consumer-protection stack anchored by the kiosk fraud-refund law, the Bitcoin Depot redress program, the breach-notification regime, and UTPA's private right of action.
all · compliance · analyst · board
Evidence 6 claims ›

W11AssessedAML/CFT & Financial Crime

Sentinel6 claims

W11 is Sentinel.gi-fed by methodology design; the dedicated feed for US-ME was not accessible this pass. Standing context is limited to statutory BSA/AML scaffolding, not original analysis.

No periodic updates yet · baseline brief is current.

W11AML/CFT & Financial CrimeAssessed
W11 is Sentinel.gi-fed by methodology design; the dedicated feed for US-ME was not accessible this pass. Standing context is limited to statutory BSA/AML scaffolding, not original analysis.
all · compliance · analyst · board
Evidence 6 claims ›

W12HighCorrespondent Banking, Settlement & Access

3 claims

Maine's smaller banks/credit unions access national settlement rails largely via correspondent providers and pooled Fed accounts, a structure the Fed proposes extending to cross-border legs.

No periodic updates yet · baseline brief is current.

W12Correspondent Banking, Settlement & AccessHigh
Maine's smaller banks/credit unions access national settlement rails largely via correspondent providers and pooled Fed accounts, a structure the Fed proposes extending to cross-border legs.
all · compliance · analyst · board
Evidence 3 claims ›

W13AssessedCommercial Intelligence (M&A, Investment & Product)

2 claims

Trailing-12-month Maine commercial activity is dominated by bank/trust consolidation (Gorham Savings/Maine Community Bancorp; Corient/H.M. Payson) rather than fintech venture funding.

No periodic updates yet · baseline brief is current.

W13Commercial Intelligence (M&A, Investment & Product)Assessed
Trailing-12-month Maine commercial activity is dominated by bank/trust consolidation (Gorham Savings/Maine Community Bancorp; Corient/H.M. Payson) rather than fintech venture funding.
all · compliance · analyst · board
Evidence 2 claims ›

Key judgments

5 judgments
W1aConfirmed
Maine's non-bank money-transmission regime (MMTMA) is comprehensive and mature, with a strong enforcement track record (Bitcoin Depot, ACI Payments, Commonwealth FX) demonstrating active licensing-compliance oversight.
Impact: HIGH
2 supporting claims
Evidence 2 claims ›
W2High
The 2025 virtual-currency-kiosk law positions Maine among the more consumer-protective state-level crypto-ATM regimes in the US, combining fee caps, transaction limits, and fraud-refund mandates.
Impact: HIGH
2 supporting claims
Evidence 2 claims ›
W4High
Maine's outright card-surcharge ban creates a distinct, standing merchant-acquiring compliance obligation, insulated from the pending national interchange-fee settlement.
Impact: ELEVATED
2 supporting claims
Evidence 2 claims ›
W6High
Bank/trust consolidation (Gorham Savings/Maine Community Bancorp; Corient/H.M. Payson) reflects continued structural consolidation among Maine's community banking and trust sector.
Impact: ELEVATED
4 supporting claims
Evidence 4 claims ›
W12Assessed
Maine's smaller banks and credit unions remain structurally dependent on correspondent providers for instant-payment rail access, a dependency the Fed's April 2026 proposal would extend to cross-border settlement.
Impact: ELEVATED
2 supporting claims
Evidence 2 claims ›

What changed this cycle

15 changes this cycle
jurisdiction US-MENew
Baseline established across 13 modules
First interpreter baseline cycle for US-ME.
Detail ›
domain W1aNew
MMTMA licensing framework established
Baseline population of W1a standing position and findings.
Detail ›
domain W1bNew
Conduct/safeguarding position established
Baseline population of W1b standing position and findings.
Detail ›
domain W2New
Digital-money/kiosk position established
Baseline population of W2 standing position and findings.
Detail ›
domain W3New
Resilience position established (thin coverage)
Baseline population of W3 standing position and findings.
Detail ›
domain W4New
Scheme/network position established
Baseline population of W4 standing position and findings.
Detail ›
domain W5New
Corridor position established
Baseline population of W5 standing position and findings.
Detail ›
domain W6New
Industry-structure position established
Baseline population of W6 standing position and findings.
Detail ›
domain W7New
Litigation position established
Baseline population of W7 standing position and findings.
Detail ›
domain W8New
Merchant-acquiring position established
Baseline population of W8 standing position and findings.
Detail ›
domain W9New
Product-innovation position established
Baseline population of W9 standing position and findings.
Detail ›
domain W10New
Consumer-protection position established
Baseline population of W10 standing position and findings.
Detail ›
domain W11New
AML/CFT sentinel-shadow position established
Baseline population of W11 standing position and findings; Sentinel feed unavailable.
Detail ›
domain W12New
Correspondent-banking position established
Baseline population of W12 standing position and findings.
Detail ›
domain W13New
Commercial-intelligence position established
Baseline population of W13 standing position and findings.
Detail ›

Risk posture

1 tracked
US-METightening Consumer-Protection/Digital-Money Regulation, Stable Core Licensing Framework
2025-26 kiosk law and Bitcoin Depot consent agreement layered onto mature MMTMA licensing regime
Risk level: Moderate
Confidence: High
Detail ›
World Payments jurisdiction data · United States — Maine (US-ME) · schema world-payments-v1 · baseline wpm-2026-07-08. Data-driven from the published jurisdiction contract — all values shown are read directly from the pipeline output (server-rendered).

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.