Current Affairs Security

Maine's Crypto Dormancy Law Is Live But Nobody Knows What the Rules Actually Are

2026-07-29

Maine's new crypto dormancy law, Public Law Chapter 675, kicks in July 29, 2026. Looks straightforward on paper. Virtual currency gets presumed abandoned after five years of no owner activity—or from the date first-class mail bounces back, whichever restarts the clock. Standard stuff for unclaimed property.

Then the manual showed up.

The State Treasurer's 2026 Holder Reporting Manual lists "VC02 Virtual Currency – Liquidated" with a three-year dormancy period. The rest of the manual respects the new law's July 29 transition date. But virtual currency? No schedule. No clarity. Just silence.

For any crypto business holding customer assets, this matters enormously. Are you reporting on a five-year clock or three? Does the old rule still apply to existing holdings? When does your first reporting cycle actually start? The law's there. The answer isn't.

The practical weight is real. If your business controls the private keys, credentials, or transfer information for dormant customer crypto, you've got a remittance duty: report it, deliver it in native form, within 30 days before filing. Follow the administrator's directions. No wiggle room.

If you don't have the keys or transfer info? You hold the assets until a transfer becomes possible. But there's a distinction: assets that only the owner can move from their own wallet aren't subject to third-party transfer obligations. You're not responsible if you genuinely can't touch it.

Liquidation gets its own layer of complexity. The state administrator can order you to liquidate within 30 days before filing, reject certain assets, grant exemptions by rule, or direct alternative disposition if liquidation isn't reasonably possible. The catch: an owner can't recover gains that happen after the state-ordered liquidation. If the administrator tells you to sell at $50,000 and the price doubles the next week, the owner gets the $50k value. That's on them.

If you deliver the actual crypto to the state instead of liquidating first, the administrator generally can't sell it for a full year. If they do sell within that window and the owner files a valid claim before the year ends, the owner gets whichever is higher: the sale proceeds or the market value at claim time, plus any applicable increments. It's a small protection, but it exists.

Maine's broader LD 1969 bill did more than virtual currency. It simplified abandonment rules for retirement accounts and other tax-deferred accounts. Real modernization. Except, you know, for the part where nobody's sure what the rules actually are.

Maryland already moved in the same direction. Their recent amendments explicitly bring virtual currency under unclaimed property law: five-year abandonment standard, 30-day liquidation-and-remit deadline before filing. At least Maryland's being consistent about it.

Maine? As July 29 creeps closer, the Treasury Department hasn't issued clear transition guidance. Affected businesses are in a genuine gray zone. Do I follow the statute's five-year rule or the manual's three-year entry? What applies to my current holdings? What applies going forward?

The law is working as intended. The execution is doing something else entirely.

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