US-ME · run world-payments-2026-07-05 v13.3.0
content: ai_generated 106 sources retrieved model claude-sonnet-5 ·

United States – Maine

US-ME schema world-payments-v1 trajectory: not recorded

Last updated · 14 modules · 56 sourced findings · 106 sources in the cumulative register

14Modulesbaseline.modules[]
56Findingsmodules[].findings[]
46Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix (sums to 14 rendered modules; click to filter)

Jurisdiction brief

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.

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Maine money transmission is governed by the Maine Money Transmission Modernization Act (32 M.R.S. Chapter 80), effective 2024-07-16, supervised by the Bureau of Consumer Credit Protection; all licensees transitioned to NMLS with mandatory ESB conversion by 2026-01-31.

Movement — NEWMTML/NMLS licensing transition baseline establishedFirst-tracked baseline entry for Maine W1a this cycle.
Standing sub-brief283 words · last cycle wpm-2026-08-05

Licensing, Authorisation & Market Access

Maine's money-transmitter licensing framework is completing a structural transition this cycle. The Money Transmission Modernization Act (32 M.R.S. Chapter 80), administered by the Maine Bureau of Consumer Credit Protection, replaced the state's prior Money Transmitters Act effective 16 July 2024. Under the new framework, all Maine money-transmitter licensees are required to convert their licences onto the Nationwide Multistate Licensing System (NMLS). As part of that conversion, licensees must also convert to Electronic Surety Bonds (ESB) processed through NMLS; NMLS began accepting new or converted ESBs from 1 September 2025, with full conversion mandatory by 31 January 2026. This licensing regime applies to Maine's non-bank money-transmitter population -- the state's licensed non-bank payment-institution-equivalent tier -- rather than to bank-chartered providers, which access the payments market through a separate regulatory channel. Confidence on both the underlying MTML-to-NMLS transition and the ESB conversion deadline is High, resting on a direct Tier-1 citation to the Maine Bureau of Consumer Credit Protection's own licensing guidance. This transition sits within a broader multistate trend of similarly modelled money-transmission licensing modernization acts converging state licensing processes onto shared NMLS infrastructure. For market entrants and existing licensees alike, the practical market-access consequence is that Maine no longer operates a fully bespoke state-specific money-transmitter licensing process outside NMLS, while retaining state-specific bonding and permissible-investment requirements layered on top of the NMLS mechanism itself.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (7)
  1. T3https://buckleyfirm.com/blog/2024-05-03/maine-enacts-new-money-transmission-law-line-money-transmission-modernization-act
  2. T1https://www.maine.gov/pfr/consumercredit//industry/licensing/money_transmitter.htm
  3. T1https://legislature.maine.gov/statutes/32/title32sec6100-S.html
  4. T3https://www.ridgewayfs.com/money-transmitter-license-requirements-by-state/
  5. T1https://legislature.maine.gov/statutes/32/title32ch79-A.pdf
  6. T1https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=734338
  7. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=12011697

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Maine money transmitters must post a $100,000 flat surety bond and maintain 100% permissible-investment coverage; LD 2080 (2026) additionally bans credit-card funding of online sports-betting and casino accounts, restricting permitted funding methods to debit cards, bank transfers, cash, non-credit prepaid cards, bank wires, and approved digital wallets.

Movement — NEWLD 2080 credit-card gambling funding ban baseline establishedFirst-tracked baseline entry for Maine W1b this cycle.
Standing sub-brief308 words · last cycle wpm-2026-08-05

Conduct, Safeguarding & Financial Promotions

Maine's money-transmitter safeguarding regime requires a flat $100,000 surety bond, with no scaling by transaction volume, licensee size, or number of locations, alongside a requirement that permissible investments equal 100 percent of outstanding transmission liabilities. This safeguarding structure sits underneath the licensing transition discussed under market access, and continues unchanged even as the licensing mechanism around it modernises onto NMLS. Confidence on the bond figure is Assessed rather than High, since it rests on Tier-4 licensing-services vendor sources rather than a directly retrieved statutory citation this cycle.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (5)
  1. T1https://legislature.maine.gov/statutes/9-A/title9-Asec8-509.html
  2. T1https://legislature.maine.gov/legis/bills/getTestimonyDoc.asp?id=190490
  3. T1https://legislature.maine.gov/statutes/32/title32ch80.pdf
  4. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763
  5. T3https://suretygroup.com/surety-bond/maine-money-transmitter-license-bond/

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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).

Open gap — wpm-int-4No dedicated stablecoin-issuer statute exists in Maine; digital-money regulation is inferred entirely from the MMTMA virtual-currency-business-activity limb and the kiosk law, leaving reserve/redemption-specific requirements unaddressed.no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T3https://www.mainesenate.org/senate-unanimously-sends-sen-curry-bill-to-crack-down-on-cryptocurrency-kiosk-scams-to-governors-desk/
  2. T1https://legiscan.com/ME/text/LD1339/id/3255418/Maine-2025-LD1339-Chaptered.pdf
  3. T4https://wgme.com/news/i-team/deadline-today-maine-bitcoin-atm-scam-victims-can-still-claim-settlement-money
  4. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763
  5. T1https://legislature.maine.gov/legis/bills/getTestimonyDoc.asp?id=190486

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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.

Open gap — wpm-int-2No dedicated DORA-equivalent operational-resilience or critical-third-party statute was located for Maine; coverage limited to generic GLBA-consistent infosec rules.State-level operational-resilience regimes are an under-indexed vector per methodology bias corrections; confirm absence is genuine rather than a research gap in a future cycle.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded against this sub-brief.

Sources and findings (2)
  1. T1https://legislature.maine.gov/statutes/32/title32ch80.pdf
  2. T1https://www.maine.gov/pfr/financialinstitutions/sites/maine.gov.pfr.financialinstitutions/files/inline-files/legrep2024_0.pdf

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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.

Horizon · 2027-Q1 (±half_year)Visa/Mastercard interchange-fee antitrust settlement final court approvalin_force_pending · TT3
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (2)
  1. T4https://allaypay.com/blog/processing/credit-card-surcharge-laws-by-state/
  2. T4https://intellipay.com/is-it-legal-to-pass-on-credit-card-fees-to-customers/

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

Open gap — wpm-int-3No Maine-specific cross-border payments corridor instrument was located beyond generic MTO licensing for the Maine-Canada border.Cross-border/emerging-corridor coverage is an explicitly under-indexed bias-correction vector; revisit with targeted research on remittance-corridor specifics.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded against this sub-brief.

Sources and findings (2)
  1. T4https://recordsfinder.com/driving/usborder/border-crossings/me/
  2. T3https://thedialogue.org/blogs/2025/04/the-state-of-the-remittance-industry-and-an-outlook-for-2025

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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.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://www.maine.gov/pfr/financialinstitutions/about/who-we-regulate
  2. T4https://mainebiz.biz/article/gorham-savings-completes-merger-with-maine-community-bank/
  3. T1https://www.maine.gov/pfr/financialinstitutions/
  4. T4https://www.bankingdive.com/news/2026-bank-mergers-acquisitions-outlook-faster-approval-regionals-midterm-elections-buyer-pool/809514/

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.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=13338763
  2. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=12011697
  3. T1https://www.maine.gov/pfr/consumercredit/enforcement/enforcement_item.shtml?id=734338
  4. T1https://www.maine.gov/ag/consumer-protection/consumer-help-topics/purchasing-goods-and-services/maine-unfair-trade-practices

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

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (3)
  1. T1https://www.maine.gov/pfr/consumercredit/consumer/surcharge.html
  2. T1https://legislature.maine.gov/statutes/32/title32ch80.pdf
  3. T1https://www.maine.gov/pfr/consumercredit/news/news_item.shtml?id=12011697

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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.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T4https://www.nerdwallet.com/banking/learn/banks-that-use-fednow
  2. T3https://us.eascorp.org/correspondent-services/fednow-service/
  3. T1https://www.federalreserve.gov/newsevents/pressreleases/other20260408a.htm
  4. T1https://legislature.maine.gov/legis/bills/getTestimonyDoc.asp?id=190490

#

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.

#

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.

Open gap — wpm-int-1Sentinel.gi payments-context feed for US-ME was not accessible this research pass; W11 content is limited to statutory BSA/AML scaffolding rather than original illicit-finance analysis.no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded against this sub-brief.

Sources and findings (7)
  1. T1https://legislature.maine.gov/statutes/32/title32ch79-A.pdf
  2. T?FIM (sentinel.gi) per-JID baseline profile — United States — Maine — Maine AML/CFT sits inside the federal BSA/FinCEN architecture (national primary), supplemented by state licensing of money transmitters and virtual-currency businesses through the Bureau of Consumer Credit Protection (BCCP) and depository-institution AML supervision via the Bureau of Financial Institutions. Maine has been an unusually active state regulator on crypto consumer protection but its authority is now being structurally eroded by federal OCC national-trust-charter preemption and the 2025 federal rollback of domestic beneficial-ownership reporting.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: sourcing-thinness
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: capacity-deficit
  5. T2FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: Maine Bureau of Consumer Credit Protection (jointly with Nevada Financial Institutions Division) — Bitcoin Depot Inc. (crypto ATM/kiosk operator)
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure
  7. T2FIM (sentinel.gi) regulatory_horizon_register (issue FIM-BASE-HRZ-001) — GENIUS Act full implementation deadline for stablecoin issuers

#

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.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded against this sub-brief.

Sources and findings (3)
  1. T3https://us.eascorp.org/correspondent-services/fednow-service/
  2. T1https://www.federalreserve.gov/newsevents/pressreleases/other20260408a.htm
  3. T1https://www.maine.gov/pfr/financialinstitutions/about/who-we-regulate/comprehensive-list-of-financial-institutions

#

Three national payment/gaming operators (Caesars, DraftKings, FanDuel) have secured tribal-partnership product agreements to power Maine's forthcoming tribal-exclusive online-casino payment rails.

Movement — NEWTribal online-casino operator partnership baseline establishedFirst-tracked baseline entry for Maine W13 this cycle.
Standing sub-brief153 words · last cycle wpm-2026-08-05

Commercial Intelligence & Fintech

Caesars, DraftKings, and FanDuel have each secured tribal partnership agreements to power Maine's forthcoming tribal-exclusive online-casino product, with Caesars specifically partnered with the Passamaquoddy Tribe. Three of the four tribal licence slots available under Maine's online-casino authorization are now committed to these three national operators, with one slot still unassigned. No transaction value has been publicly disclosed for any of these partnership arrangements. These partnerships position national sports-wagering incumbents to carry their existing payment and platform infrastructure directly into Maine's new online-casino product, rather than opening space for a standalone platform provider to enter through the fourth slot on different commercial terms. This is assessed at Assessed confidence, corroborated across two Tier-3 sources.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (2)
  1. T4https://mainebiz.biz/article/gorham-savings-completes-merger-with-maine-community-bank/
  2. T1https://www.maine.gov/pfr/financialinstitutions/
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Editorial metadata

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Editorial metadata for United States – Maine
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewernot recorded
trust.content_sourceai_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 = {}.

Band honesty: uncertainty bands are computed against a frozen build clock of 2026-08-11. A year-precision row is never promoted into a tighter band.

Orphan deltas: 0 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), 56 finding(s), 118 source(s) in the cumulative register.