The Maryland Money Transmitter License guide (Faisal Khan LLC, July 2026) covers Fin. Inst. §§ 12-401–12-431 and COMAR 09.03.14, administered by the Office of Financial Regulation in Baltimore, with a capital formula the guide says most third-party summaries understate by 50%.
The number worth catching: tangible net worth is $150,000 GAAP plus $10,000 per licensed location or authorized delegate, up to $500,000 — so a 20-delegate network already requires $350,000, not the $150,000 floor alone. Maryland did not adopt the MTMA net worth formula, and a shortfall unremedied within 10 days of written notice is grounds for suspension or revocation. Two statutory fees are due up front — $1,000 investigation plus $2,000 license — and if the application is denied, the OFR keeps both.
Crypto is widely misreported here: the Act defines no "virtual currency" term at all, so claims that Maryland "explicitly treats virtual currency as money" aren't supported by the statute — crypto is assessed under the general "value that substitutes for currency" definition instead. Kiosks run under a separate 2025 registration regime (COMAR 09.03.16), and holding an MTL does not relieve a kiosk operator of that separate registration.
What the guide covers:
- The surety device: greater of $150,000 or 100% of average daily Maryland liability, capped at $2,000,000
- A three-year money-transmission experience requirement for a principal officer or member under §12-406(a)(4)
- Quarterly MSB Call Reports and quarterly UAAR filings, both easy to miss
- The real renewal deadline — 17 December, not 31 December, to preserve trading continuity
- Exemptions limited to banks, credit unions, the federal government and a few narrow categories
- Unlicensed activity as a felony under §12-430, up to five years' imprisonment
The 2027 Maryland Stablecoin Act will make OFR the state's stablecoin regulator.