Maryland Virtual Currency Unclaimed Property Amendments

Maryland Virtual Currency Unclaimed Property Amendments refers to the virtual-currency provisions in the 2025 revisions to the Maryland Uniform Disposition of Abandoned Property Act. The cross-filed measures, SB 665 and HB 761, were approved by the Governor on May 20, 2025 as Chapters 635 and 636 and took effect on Oct. 1, 2025. The law brings certain virtual currency into Maryland’s abandoned-property framework, administered by the State Comptroller.

Maryland Unclaimed Property Act Crypto Scope

The amendments add “virtual currency” to Maryland Commercial Law Article Title 17. The current statutory definition covers a digital representation of value used as a medium of exchange, unit of account, or store of value that does not have U.S.-recognized legal tender status. It excludes the software or protocols governing transfer, game-related digital content, and loyalty cards.

The statute also modernizes owner-interest concepts that matter for dormancy analysis. “Indication of apparent owner interest” includes recorded communications with the holder, certain oral communications preserved by the holder, dividend or distribution activity, account access, directions to change the amount or type of property held, deposits or withdrawals, and other actions reasonably showing the apparent owner knows the property exists.

Five-Year Abandonment Rule for Virtual Currency

The crypto-specific rule is codified in new Commercial Law §17-307.2. Virtual currency is presumed abandoned if it remains unclaimed five years after the last indication of apparent owner interest in the property. That is the main dormancy rule for covered virtual currency under the Maryland amendments.

The statute uses a liquidation-and-remittance model, not a native-token transfer model. Within 30 days before filing the abandoned-property report required under §17-310, a holder of abandoned virtual currency must liquidate the virtual currency and remit the liquidation proceeds to the administrator. The owner has no right of recourse against either the holder or administrator to recover gains in value that occur after the required liquidation.

Reports, Notices, and Claims

Maryland’s general reporting statute requires holders of presumed abandoned property to report to the administrator and include owner, property, transaction, and other prescribed information. The general report period runs from July 1 through June 30 and is due no later than Oct. 31, while insurance corporations use a calendar-year reporting period with reports due April 30.

The holder notice rule remains important for owner outreach. Not more than 120 days and not less than 30 days before the required report, a holder in possession of presumed abandoned property valued at $100 or more must send written notice by first-class mail to the apparent owner’s last known address, stating that the holder has property subject to Title 17 and that the property will be considered abandoned unless the owner responds within 30 days.

The 2025 revisions also changed related claim mechanics. The administrator may waive the claim-filing requirement for certain apparent owners where the administrator reasonably believes the person is entitled to property or payment valued at $5,000 or less. After a claim is allowed, the administrator must deliver the property or pay net sale proceeds within six months, subject to the statutory debt-offset provisions.

Jurisdictional Impact

This is a Maryland state-law profile within the United States. It is most relevant to exchanges, custodians, hosted-wallet providers, financial institutions, payment companies, and other holders that may possess virtual currency owed to apparent owners under Maryland abandoned-property law. The profile should not be read as a federal crypto custody rule, a money-transmission licence, a securities classification rule, or a tax regime.