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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.

Conditional AI-Generated · Unreviewed

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).

licensing 100% confidence

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

licensing 90% confidence

Unlike full licensing (e.g., with ongoing supervision), this is entry-based but mandates ongoing AML/KYC and reporting to UIF/CNV.

licensing 100% confidence

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

licensing 95% confidence

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).

licensing 90% confidence

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

licensing 60% confidence

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

licensing 20% confidence

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

licensing 20% confidence

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

licensing 20% confidence

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

licensing 20% confidence

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

licensing 20% confidence

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

licensing 20% confidence

Argentine Federal Administration of Public Revenue (AFIP): Enforces tax obligations on crypto-related activities, including capital gains reporting

licensing 70% confidence

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.

aml 20% confidence

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

aml 20% confidence

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

aml 20% confidence

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

aml 20% confidence

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

aml 85% confidence

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).

aml 90% confidence

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

aml 85% confidence

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

aml 95% confidence

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

aml 85% confidence

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.

aml 95% confidence

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

aml 20% confidence

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).

aml 20% confidence

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.

aml 20% confidence

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.

aml 20% confidence

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

aml 20% confidence

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

aml 20% confidence

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

tax 20% confidence

Law 27,739 (2024): Integrates VASPs into AML/KYC framework; registration with CNV required.

tax 85% confidence

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).

tax 95% confidence

AFIP Ruling 2/2022: Classifies crypto as digital assets under Personal Property Tax framework.

tax 95% confidence

Law 27.743: Mandatory crypto declaration for tax/regularization.

tax 95% confidence

Impuesto a las Ganancias (Ley 20.628): Covers CGT/income.

enforcement 20% confidence

Regulator: Buenos Aires Court (Judge Susana Parada)

enforcement 20% confidence

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.

enforcement 20% confidence

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.

enforcement 20% confidence

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.

enforcement 20% confidence

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.

aml 20% confidence

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?