Centralized exchange in Argentina
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Argentina with a local entity, subject to AML obligations and medium licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- Medium
- Last updated
- 2026-07-13
AML Obligations
- Register with CNV's VASP registry (PSAV) under Law 27,739 and CNV General Resolution 994/2024
- Register with UIF under Resolution 49/2024 for AML compliance
- Minimum net worth of $5,000–$50,000 (classification-dependent); half in cash for new applicants
- Implement strict Know Your Customer (KYC) procedures and continuous risk-based transaction monitoring
- Report suspicious activities to the Financial Information Unit (UIF) within 150 days
- Conduct continuous, risk-based screening against OFAC SDN, EU/UN sanctions lists, and Argentina's RePET list
- Report blocked assets to OFAC/UIF; no dealing with sanctioned entities or crypto from sanctioned sources
- Appoint a mandatory compliance officer
- Collect, transmit, and retain originator/beneficiary information for in-scope crypto-asset transfers (Travel Rule under FATF Rec. 16)
- Systematic reporting for higher-value activity; first annual compliance audit cycle from 1 January 2026
- Comply with CNV Resolution 1058/2025 mandatory registration deadlines (foreign entities by 1 September 2025)
Key Restrictions
- Must incorporate a local entity (SA or SRL/LLC) with at least 1 local director and 2 shareholders
- Must register with CNV as a VASP before operations; unregistered VASPs cannot function
- Full AML/CFT and Travel Rule framework enforceable since 31 December 2025; first audit cycle from 1 January 2026
- Strict rules on unhosted wallets and inbound cross-border transfers under the Travel Rule
- Traditional banks can offer crypto services from April 2026 under supervision (potential future competition)
- Monthly volume threshold of 35,000 UVA (~$29,246) triggers mandatory registration
Key Risks
- Regulatory framework is still evolving — CNV Resolution 1025 (draft) proposes finalized VASP rules on custody infrastructure, audits, and policies, creating some forward-looking ambiguity
- BCRA is reviewing a potential lift on the bank prohibition for crypto trading/custody, which may reshape the competitive landscape
- Enforcement precedent: Coinbase suspended ARS-to-USDC trading after less than one year; Polymarket was blocked nationwide; CoinX was banned for operating without authorization
- Unregistered platforms face elevated enforcement risk including access blocks, ISP restrictions, and app store removals
- Travel Rule compliance requires FATF-aligned data transmission; no specific protocols mandated yet, creating implementation uncertainty
- Tax obligations under AFIP (capital gains reporting) and Law 27,743 (declaration of crypto holdings for asset regularization) add compliance layers
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Argentina’s CNV regulates Virtual Asset Service Providers through its PSAV/VASP registry on cnv.gov.ar, but the regime has since evolved into a more detailed licensing/registration framework with ongoing supervisory, reporting, and compliance requirements; it is not just a simple static registry claim.
Law N° 27,739: https://www.boletinoficial.gob.ar/detalleAviso/primera/296092/20240314 (via ).
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.
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)
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.
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).
RePET list: Primary Argentine list for terrorism/financing; VASPs must screen, high quality for region.
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.
The Travel Rule is fully live and enforced as a core PSAV compliance requirement, aligning with FATF standards.
Key timeline: Law 27.739 (March 2024) defined PSAVs; phased CNV registration in 2025; full enforceability of AML/CFT and Travel Rule obligations on 31 December 2025; first compliance audit cycle from 1 January 2026.
CNV Resolution 1058/2025 (March 2025) mandated VASP registration with staggered deadlines: individuals by 1 July 2025, Argentine entities by 1 August 2025, foreign entities by 1 September 2025.
VASPs must collect, transmit, and retain originator/beneficiary information for in-scope crypto-asset transfers.
Systematic reporting for higher-value activity; first annual audits from January 2026.
Strict on unhosted wallets and inbound cross-border transfers.
Entity Targeted: Polymarket (crypto-powered prediction platform). Violation Type: Operating as an unlicensed online betting service without identity or age verification. Penalty: Nationwide access block; directed ISPs to restrict access; Google and Apple instructed to remove mobile applications. Outcome: Platform blocked countrywide.
Entity Targeted: President Javier Milei (for promoting $LIBRA cryptocurrency). Violation Type: Market manipulation; alleged rug pull scam. Penalty Amount: $251 million in investor losses documented. Outcome: Over 100 criminal complaints filed; judicial investigation launched; described as "Cryptogate" and The Economist called it the "first big scandal" of Milei's presidency.
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.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange may operate in Argentina only after registering as a VASP (PSAV) with the CNV and UIF, incorporating a local entity, meeting capital requirements ($5K–$50K), and complying with a full AML/KYC/Travel Rule framework enforceable since 31 December 2025.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?