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Maine unhosted-wallet controls for digital-asset businesses

A Maine money-transmission licensee sending virtual currency to an unhosted wallet must identify the recipient; the sender’s attestation alone is insufficient when the sender claims to be the recipient. Maine’s May 2025 advisory ruling says the rule applies to transfers of $3,000 or more and accepts blockchain analytics or another reasonable method to evidence sender control in that self-recipient scenario. This is a licensee workflow issue, not a rule for every digital-asset business. 1,2

What Is Digital Assets?

Digital-asset coverage may address custody, theft and business-liability risks, but a custodian’s policy may protect the custodian rather than you. If you hold or safeguard assets, verify the insured entity, wallets, key-loss protection and valuation. Read the national Digital assets guide.

Maine Requirements

RequirementDetails
Build the qualifying destination checkFor covered licensees and transactions at or above the advisory’s $3,000 equivalent threshold, identify the recipient for an unhosted-wallet transfer. A sender’s claim that they are the recipient is not enough by itself. 1,2
Keep evidence of control checksThe Bureau says a licensee may satisfy the requirement in the sender-is-recipient scenario with blockchain analytics or another procedure that reasonably evidences ownership or control, such as a Satoshi test. 2

What to Watch for in Maine

  • The statute applies to licensees

    Section 6100-UU addresses a licensee. Do not apply the specific transfer rule to a business or activity outside the Maine Money Transmission Modernization Act without checking scope. 1,2

  • The $3,000 threshold comes from the advisory

    The statute text does not include that dollar threshold; the Bureau’s May 2025 advisory ruling says its interpretation applies at $3,000 or more in U.S. dollar equivalent. 2,3

  • Verification does not settle loss allocation

    The recipient-identification control may reduce a misdirected or scam transfer risk, but it does not make an insurer responsible for the transfer or determine whether the licensee or customer bears the loss. 2,4,5

Who Regulates Insurance in Maine

Maine Bureau of Insurance

The Maine Bureau of Insurance licenses producers and companies, enforces Maine insurance laws, and investigates property and casualty complaints including commercial coverage complaints. You can use its state lookup or complaint service to check a license or raise an insurance issue. 6,7,8

Surplus-lines tax and stamping office

Reported tax rate: 3% of gross direct premium when Maine is the insured's home state Maine charges 3% of gross direct premium when it is the insured's home state; your broker handles the tax and may include it with the premium. Surplus-lines policies are outside Maine guaranty-association protection. Maine generally requires a diligent search, with an exempt-commercial-purchaser exception requiring broker disclosure and the purchaser's written request. 9,10,11

Providers With Documented State Licenses

No provider in Spot’s research documents both a state license record and this coverage line. This does not establish that providers are unlicensed. Check the regulator’s license lookup and confirm availability with a provider when requesting a quote.

Questions to Ask Before You Buy in Maine

  1. Are you a covered Maine licensee transmitting to an unhosted wallet, or are you only a software, wallet or custodian provider?
  2. What procedure beyond customer self-attestation verifies the recipient or sender’s control for transactions subject to the advisory?
  3. Which employee or service provider conducts analytics or control testing, and where are records retained?
  4. Ask the broker whether customer transfer liability, employee error, external theft and custody loss are treated distinctly under the actual policy.

Digital Assets in Maine: FAQ

Can a Maine licensee rely only on a sender saying that an unhosted wallet is theirs? 1,2

No. Section 6100-UU says the sender’s attestation alone is insufficient when the sender claims to be the recipient. The Bureau’s advisory describes additional ways to evidence control. 1,2

Does the $3,000 threshold appear in the statute? 2,1

The threshold appears in the Bureau’s May 2025 advisory ruling, which says the section applies to transactions of $3,000 or more in U.S. dollar equivalent. The quoted statute itself states the recipient identification rule without that amount. 2,1

Digital Assets in Other States

Other Coverage in Maine

Sources

  1. 32 M.R.S. §6100-UU, Requirements for unhosted wallets. Maine Legislature; Current codified text; licensee must identify recipient; sender’s attestation alone insufficient where sender claims to be recipient. Accessed 2026-09-28.
  2. Maine Money Transmission Modernization Act Advisory Ruling 1. Maine Bureau of Consumer Credit Protection; May 14, 2025 ruling; pp.1–2, purpose, $3,000 threshold, recipient identification and reasonable evidence of wallet ownership/control. Accessed 2026-09-28.
  3. Bureau Publishes Money Transmission Modernization Act Advisory Ruling. Maine Bureau of Consumer Credit Protection; May 15, 2025 notice identifying the ruling as guidance under §6100-UU. Accessed 2026-09-28.
  4. Insurance. BitGo; Current page: custody and key-control description; direct-insured entity and location/entity eligibility qualifiers. Accessed 2026-09-28.
  5. Performance Management — Supplemental Requirements & Guidance. Lloyd’s; January 2020, pp.44–46: historic underwriting considerations for key security, hot/cold storage, code/network risk, insured identity and valuation; historical market guidance only. Accessed 2026-09-28.
  6. Maine Bureau of Insurance. Maine Bureau of Insurance; Homepage and commercial insurance resources. Accessed 2026-09-28.
  7. Insurance License Lookup. Maine Bureau of Insurance; State-designated producer/company search. Accessed 2026-09-28.
  8. File an Insurance Complaint. Maine Bureau of Insurance; State complaint process and contact. Accessed 2026-09-28.
  9. 36 M.R.S. §2531. Maine Legislature; 36 M.R.S. §2531(1)-(2), current page: home-state basis; 3% tax; producer pays on chapter 19 surplus lines. Accessed 2026-09-28.
  10. 24-A M.R.S. §4433. Maine Legislature; Surplus-lines contracts excluded from guaranty association. Accessed 2026-09-28.
  11. 24-A M.R.S. §2002-A. Maine Legislature; ECP disclosure and written-request procedure. Accessed 2026-09-28.
  12. Licenses. At-Bay; Current producer introduction and state table; At-Bay Insurance Services LLC; P&C and surplus-lines identifiers. Accessed 2026-09-21.
  13. Licenses and Carriers. Coalition; Licenses and Carriers, re-read 22 September 2026: Insurance Licenses table for Coalition Insurance Solutions, Inc., national producer number 18419475, with producer and surplus-lines numbers for all 50 states and DC including California 0L76155, Georgia 196479, Texas 2199630 and 2205589, Pennsylvania 815731 and 817452, Colorado 539028 and Wisconsin 3000108852. Insurance Carriers table naming, with NAIC numbers, Allianz Underwriters Insurance Company 36420, Arch Specialty Insurance Company 21199, Ascot Specialty Insurance Company 45055, Ascot Insurance Company 23752, Aspen Specialty Insurance Company 10717, Chaucer Insurance Company DAC, Coalition Insurance Company 29530, Fireman's Fund Indemnity Corporation 11380, Fortegra Specialty Insurance Company 16823, Lloyd's of London, MSIG Specialty Insurance USA Inc. 34886, MS Transverse Specialty Insurance Company 41807, Steadfast Insurance Company 26387, Vantage Risk Specialty Insurance Company 16275 and Zurich American Insurance Company 16535. Accessed 2026-09-22.
  14. Insurance Producer Licenses. Corgi Insurance; Current complete Insurance Producer Licenses table for Corgi Insurance Services, Inc.; 50 rows covering 49 states and DC (DC 3003091619); no New Mexico row; no NPN or as-of date shown. Accessed 2026-09-28.
  15. About Hiscox US Insurance. Hiscox; Hiscox Insurance Company Inc. NAIC 10200 as Chicago, IL domiciled insurer admitted or licensed in all 50 states and D.C.; Hiscox Inc. as general agent and Lloyd’s coverholder for Syndicates 33 and 3624; surplus-lines placements through licensed surplus-lines brokers; A.M. Best rating statement. Accessed 2026-09-16.
  16. Licenses. ERGO NEXT Insurance; Current entity-by-state license table reopened 28 September 2026: 50 rows under Next First Insurance Agency, Inc., including Washington, DC; New York rows instead list Next Insurance Services PC-1423070 and AP Intego BR-1198885. Accessed 2026-09-28.
  17. Insurance Licenses by State. TechInsurance; Current state table; identifies TechInsurance as a division of Specialty Program Group LLC d/b/a SPG Insurance Solutions; lists DC 3000041536 and labels Rhode Island “Individual licenses,” without an agency license number. Accessed 2026-09-28.
  18. Licenses. Vouch; Effective 16 January 2025: Vouch Specialty Insurance Services, LLC, NPN 19926463; P&C table (50 states and DC); surplus-lines table includes Idaho 870820; footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses; Idaho retained as producer-only due to conflict. Accessed 2026-09-15.

Updated .

This guide is informational and does not determine whether a policy is available or meets your needs. Editorial policy. To suggest a correction, contact Spot with a supporting source.

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