Crypto-funded debit card in Argentina
A card program where customer fiat balances are funded from crypto holdings, typically through an off-ramp at point of sale or top-up.
Crypto debit card is conditionally permitted in Argentina with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- CNV registration as a VASP (PSAV) under Law 27,739 and CNV Resolution 994/2024 for any business with monthly volumes exceeding 35,000 UVA (~$29,246)
- UIF registration under Resolution 49/2024 as a mandatory AML reporter (Sujeto Obligado)
- Implementation of strict KYC procedures and continuous risk-based transaction monitoring under CNV and UIF standards
- Reporting of suspicious activities to the UIF within 150 days per Law 25,246 and AML framework
- Continuous risk-based screening of customers, wallets, and transactions against OFAC SDN, EU/UN sanctions lists, and Argentina's RePET terrorism list
- Appointment of a mandatory compliance officer
- First annual compliance audit cycle started 1 January 2026 under fully enforceable framework
- Reporting of blocked assets to OFAC/UIF; prohibition on dealing with sanctioned entities or crypto from sanctioned sources
- Tax obligations under AFIP: declaration of crypto holdings (Law 27,743), capital gains reporting under Impuesto a las Ganancias (Ley 20.628), and Personal Property Tax (AFIP Ruling 2/2022)
Key Restrictions
- Must incorporate a local entity (SA or SRL/LLC) with 1 local director and 2 shareholders; virtual office permitted
- BCRA bank prohibition on crypto services by banks remains in place (though under review for potential lifting), limiting partner-bank/BIN-sponsor arrangements
- Crypto-to-fiat conversion at point of sale (off-ramp) requires VASP registration — no specific e-money license framework identified; the VASP license covers conversion activity
- Minimum net worth of $5,000–$50,000 depending on license classification (e.g., $50,000 for money transmitters); half in cash for new applicants
- Unregistered VASPs cannot operate — Polymarket and CoinX enforcement actions demonstrate aggressive blocking and removal for non-compliance
- Coinbase suspended ARS-to-USDC trading operations in Argentina, signaling operational risk for crypto-off-ramping arrangements
Key Risks
- No dedicated e-money or payment-institution license exists for crypto debit cards — the VASP registration framework under CNV/UIF is the applicable regime, creating ambiguity on precise licensing pathway
- BCRA bank prohibition on crypto services limits ability to secure local partner-bank or BIN-sponsor arrangements; reliance on foreign BIN sponsors may present regulatory gaps
- Enforcement risk is active: Polymarket received nationwide ISP block, CoinX was banned as Ponzi-like, and President Milei's $LIBRA promotion triggered 100+ criminal complaints
- Tax treatment is complex: crypto-to-crypto trades and DeFi disposals are taxable events, with worldwide income for residents under Impuesto a las Ganancias
- OFAC/UIF sanctions strict liability can result in civil fines up to $1M+ per violation and criminal penalties up to 30 years
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Registration-focused: Businesses register in the CNV's VASP registry for legal operation; unregistered VASPs cannot function.
Unlike full licensing (e.g., with ongoing supervision), this is entry-based but mandates ongoing AML/KYC and reporting to UIF/CNV.
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)
Argentine Federal Administration of Public Revenue (AFIP): Enforces tax obligations on crypto-related activities, including capital gains reporting
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.
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).
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.
Law 27,739 (2024): Integrates VASPs into AML/KYC framework; registration with CNV required.
Businesses/VASPs: Register with Comisión Nacional de Valores (CNV) per Law 27.739 (2024); comply with AML/CFT (FATF-aligned). Declare under asset regularization (blanqueo, Law 27.743).
AFIP Ruling 2/2022: Classifies crypto as digital assets under Personal Property Tax framework.
Law 27.743: Mandatory crypto declaration for tax/regularization.
Impuesto a las Ganancias (Ley 20.628): Covers CGT/income.
Regulator: Buenos Aires Court (Judge Susana Parada)
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.
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.
BCRA is reviewing plans to lift the bank prohibition on crypto trading/custody, debating custody requirements, capital treatment, and permitted tokens; approval would enhance consumer protection and AML.
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 crypto-funded debit card operator can operate in Argentina by registering as a VASP (PSAV) with the CNV under Law 27,739, incorporating a local entity, meeting net worth requirements ($5K–$50K), complying with full UIF AML/KYC obligations, and navigating the current BCRA banking prohibition on crypto services which complicates local partner-bank and BIN-sponsor arrangements.
Questions this verdict aims to answer
- What e-money / payment-institution license is required?
- How is the crypto-to-fiat conversion regulated?
- What KYC and AML obligations apply to cardholders?
- What partner-bank or BIN-sponsor arrangements are required?