Argentina -- Sanctions Compliance Regulatory Overview

Argentina does not impose cryptocurrency-specific sanctions but requires Virtual Asset Service Providers (VASPs) and financial entities to comply with international OFAC, EU, and UN sanctions regimes, alongside screening against its national RePET list. This stems from Argentina's anti-money laundering (AML) framework under the Financial Information Unit (UIF), which mandates VASPs—regulated as "proveedores de servicios de activos virtuales" since 2023—to implement risk-based controls for sanctions evasion, including customer and transaction screening.[2]

OFAC, EU, and UN Sanctions Compliance for VASPs

VASPs in Argentina must adhere to OFAC rules due to their extraterritorial reach, blocking assets of SDN-listed persons (including crypto addresses) and prohibiting transactions with sanctioned parties, with strict liability for violations; non-US entities risk secondary sanctions if involving US dollars, persons, or infrastructure.[3][4][5] EU sanctions apply to entities operating in or with EU ties, targeting crypto facilitators like Russian providers.[1][3] UN sanctions are universally binding but unevenly enforced globally.[3] Argentine VASPs integrate these via UIF guidelines, screening for sanctioned wallets, mixers (e.g., post-Tornado Cash delisting risks remain), and evasion networks.[1][4][5]

Sanctioned Entity Screening Obligations

• VASPs must conduct continuous, risk-based screening of customers, wallets, and transactions against OFAC SDN (93% quality score), EU/UN lists, and Argentina's RePET list (76% quality score: Registry of Persons and Entities Linked to Acts of Terrorism and Their Financing).[2][4][6]
• Report blocked assets to OFAC/UIF; no dealing with 50%+ owned entities or crypto from sanctioned sources (e.g., Blender.io, SUEX).[4][5]
• Legal basis: Law 25,246 (AML), UIF Resolution 94/2023 for VASPs; RePET under National Law 26,268.[2]

Geographic Restrictions

No blanket crypto bans, but transactions involving sanctioned jurisdictions (e.g., OFAC's Cuba, Iran, North Korea, Syria; EU/UN equivalents) are prohibited for VASPs. Argentina screens for exposure without geographic crypto blocks, unlike some nations.[1][3][4]

Penalties for Violations

• OFAC: Civil fines up to $1M+ per violation, criminal up to 30 years/$1M; strict liability.[4][5]
• Argentina: UIF fines up to ARS 10M (~$10K USD equivalent, adjusted), license revocation, criminal charges under Penal Code Arts. 303-309 for terrorism financing.[2]
• EU/UN: Varies by member state enforcement; secondary risks amplify.[3]

Country-Specific Sanctions Lists for Crypto

• RePET list: Primary Argentine list for terrorism/financing; VASPs must screen, high quality for region.[2] No dedicated crypto sanctions list; RePET integrates with global ones. OFAC SDN includes crypto identifiers.[5][7]

For legal texts: RePET at https://www.argentina.gob.ar/seguridad/rep; UIF VASPs at https://www.argentina.gob.ar/uif; OFAC SDN search at https://sanctionssearch.ofac.treas.gov.[2][7] Consult UIF or legal experts for 2026 updates, as regimes evolve rapidly.[1]