Maine's new virtual currency unclaimed-property law (Chapter 675) takes effect July 29, 2026, establishing a five-year dormancy period for crypto. But the state treasurer's 2026 Holder Reporting Manual still lists a three-year period, creating a conflict that leaves businesses holding customer crypto without clear transition instructions.
The manual vs. the statute
The manual doesn't specify the first reporting cycle under the new law or provide any transition guidance. Holders are left guessing when to report and what dormancy period applies. The law says five years; the manual says three. No word on which takes precedence. That's a headache for compliance teams.
What holders must do
If they possess private keys or credentials, holders must report and deliver presumed-abandoned virtual currency in native form within 30 days before filing. For amounts of at least $1,000, they must send certified mail at least 60 days before filing if they have a valid owner address. That's a tight timeline and a specific notification requirement.
Liquidation and owner protections
The administrator may direct liquidation of virtual currency, but owners cannot recover gains after such liquidation. However, there's a notable protection: if the state sells within one year and the owner files a claim before the year expires, they receive the greater of sale proceeds or claim-time market value. That's a rare upside for owners in unclaimed-property law.
Broader state-level crypto moves
Arizona and Oregon recently passed laws embracing Bitcoin. Meanwhile, a $239 billion claim on dormant Bitcoin wallets faces a new obstacle. Maine's law adds to the patchwork of state regulations, but the immediate confusion over the dormancy period could trip up businesses.
The unresolved question: will the treasurer update the manual to align with the statute, or will holders have to navigate the discrepancy? The July 29 effective date is tomorrow.
