Custodial wallet / SaaS in Argentina

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.

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

Law N° 27,739: https://www.boletinoficial.gob.ar/detalleAviso/primera/296092/20240314 (via ).

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.

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.

Moneyval Evaluation: Moneyval reported Argentina’s implementation of the Financial Action Task Force (FATF) recommendations as “Essentially compliant” for digital asset services in its 2023 review.

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).

CNV General Resolution N°1025 (draft, public consultation October 2024) proposes finalized VASP rules on custody infrastructure, audits, and policies, expected to align closely with the draft.

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.

Ongoing evolution includes greater clarity on institutional custody, reporting, and risk management.

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.

Adopted through Law 27.739 (March 2024), which defines PSAVs, followed by phased registration in 2025 and UIF Resolution 49/2024.

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: 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.

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.

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