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US-MD (US-MD) · Module W7 · Derived Confidence: Confirmed

US-MD: Legal & Litigation

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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 2026133 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 unique sources · R-3/R-4)
  1. [W7-E1] T1 Derived: Confirmed in_forcehttps://caselaw.findlaw.com/court/md-court-of-special-appeals/1716706.html re-verified

    The Court of Special Appeals held that CashCall engaged in an unlicensed 'credit services business' in Maryland and upheld the Commissioner's imposition of a $5,651,000 civil penalty across more than 5,000 loans arranged for Maryland consumers at rates as high as 96% APR.

  2. [W7-E2] T1 Derived: Confirmed in_forcehttps://www.mdcourts.gov/data/opinions/cosa/2022/1012s21.pdf re-verified

    In the Matter of Cash-N-Go, the Commissioner's Division found that a licensed check-cashing/pawnbroker business was offering unlicensed consumer loans under the guise of 'title pawns,' and the appellate court held the Division's assessment of penalties and restitution did not violate the Excessive Fines Clause.

  3. [W7-E3] T1 Derived: Confirmed in_forcehttps://labor.maryland.gov/whatsnews/ofrjoins80menforcementactionagainstblockinccashapp.shtml re-verified

    OFR joined an $80 million multistate enforcement action against Block, Inc. and Cash App for BSA/AML violations, with Maryland set to receive approximately $1.6 million, after state regulators found Block was not in compliance with certain due-diligence requirements.

  4. [W7-E4] T1 Derived: Confirmed in_forcehttps://mgaleg.maryland.gov/mgawebsite/laws/StatuteText?article=gcl&section=12-514 re-verified

    Under Commercial Law §12-514, a Commissioner's enforcement order becomes final either after expiration of the Administrative Procedure Act appeal window or after a final court decision affirming the order, establishing the procedural backbone for OFR enforcement actions.