Crypto ATM / kiosk operator in Argentina

Registration-focused: Businesses register in the CNV's VASP registry for legal operation; unregistered VASPs cannot function.

CNV Resolution No. 1058/2025 updates emphasize transparency and compliance.

Minimum net worth of $5,000–$50,000 (classification-dependent) for contractor licenses; half in cash for new applicants; varies by license type (e.g., $50,000 for money transmitters).

AML/KYC: Robust policies for client identification, transaction monitoring, and FATF-aligned reporting (e.g., suspicious activities to UIF); mandatory compliance officer.

Local presence: Incorporate a local entity (e.g., SA or SRL/LLC) with 1 local director and 2 shareholders; virtual office allowed.

Additional: Clean criminal record (sworn statement, no money laundering convictions); business plan, management details.

Mandatory registration for crypto businesses with monthly volumes exceeding 35,000 UVA (approximately $29,246)

Compliance with CNV Resolution 994/2024, which established the VASP registration framework

Implementation of strict Know Your Customer (KYC) procedures and continuous transaction monitoring

Reporting of suspicious activities to the Financial Information Unit (UIF) within 150 days

Financial Information Unit (UIF): AML/CFT authority; stablecoin service providers are classified as Sujetos Obligados (mandatory reporters)

FATF Assessment: Argentina is listed on the FATF “Updated Travel‑Rule Monitoring List” as “Fully cooperative,” indicating adherence to cross‑border AML/CFT requirements for virtual asset service providers.

Law 27,739 (2024): Establishes the VASP registry under CNV oversight and amends AML laws to include VASPs.

CNV General Resolution 994/2024: Defines VASPs and requires CNV registration for legal operations.

UIF Resolution 49/2024: Mandates VASP registration with UIF for AML compliance.

Anti-Money Laundering Law No. 25,246: Core law preventing money laundering, now extended to VASPs.

Supporting resolutions: CNV General Resolution 1025 (October 2024 draft on VASP rules); CNV Resolution 1058/2025 (mandatory registration deadlines, net worth, AML standards).

VASPs must conduct continuous, risk-based screening of customers, wallets, and transactions against OFAC SDN, EU/UN lists, and other relevant global and national sanctions lists (e.g., OFSI, Argentina's RePET).

Report blocked assets to OFAC/UIF; no dealing with 50%+ owned entities or crypto from sanctioned sources (e.g., Blender.io, SUEX).

Legal basis: Law 25,246 (AML), UIF Resolution 242/2023 (and modifications) for VASPs; RePET under National Law 26,268.

OFAC: Civil fines up to $1M+ per violation, criminal up to 30 years/$1M; strict liability.

Argentina: UIF fines up to ~ARS 13.5M (~$13.5K USD equivalent, adjusted; 35% increase), license revocation, criminal charges under Penal Code Arts. 303-309 for terrorism financing.

RePET list: Primary Argentine list for terrorism/financing; VASPs must screen, high quality for region.

National Securities Commission (Comisión Nacional de Valores, CNV): Primary regulator overseeing VASP registration, compliance, investor protection, and development of the crypto framework. It manages the mandatory VASP registry and recently issued General Resolution No. 1125/2026, allowing virtual assets like Bitcoin and Ethereum to count toward net worth for qualified investor status (threshold around $479,000).

Financial Information Unit (Unidad de Información Financiera, UIF): Enforces AML/CTF rules, sets transaction reporting requirements, and aligns with FATF guidelines. VASPs must comply with its standards.

Law N°27,739 (March 2024): Establishes the formal regulatory framework for VASPs, mandates CNV registration, and integrates AML/KYC processes. Full framework takes effect December 31, 2025.

Law 27,743: Requires users to declare crypto holdings for tax purposes as part of asset regularization (blanqueo).

General Resolution No. 1125/2026 (CNV): Recognizes virtual assets in net worth calculations for qualified investors.

Fully enforceable since 31 December 2025, with the first annual compliance audit cycle starting 1 January 2026; obligations are live and enforced in 2026.

Applies to registered PSAVs with Argentina's CNV (Comisión Nacional de Valores), including domestic and foreign entities targeting Argentine users.

Regulator: National Securities Commission (CNV) under Law 27,739 (passed March 2024)

Violation Type: Regulatory compliance requirements; FATF-aligned VASP oversight. Outcome: Coinbase suspended ARS-to-USDC trading operations after less than one year in the market.

Entity Targeted: CoinX crypto platform. Violation Type: Operating without authorization; operating similar to a Ponzi scheme. Outcome: Platform banned; thousands of investors affected with millions in losses.

Legal basis: Law 25,246 (AML), UIF Resolution 94/2023 for VASPs; RePET under National Law 26,268.