On-shore VASP in Argentina
Locally-incorporated VASP that operates under full local jurisdiction, holding all required licenses and registrations.
On-shore VASP 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 (PSAV) registry (Law 27,739 / CNV Resolution 994/2024) — mandatory for legal operation
- Register with UIF as a mandatory reporter (Sujeto Obligado) under UIF Resolution 49/2024
- Implement robust KYC/AML policies: customer identification, continuous transaction monitoring, risk-based screening
- Screen customers, wallets, and transactions against OFAC SDN, EU/UN sanctions lists, and Argentina's RePET list
- Report suspicious activities to UIF within 150 days
- Appoint a mandatory compliance officer
- Collect, transmit, and retain originator/beneficiary information for crypto-asset transfers (Travel Rule, aligned with FATF Recommendation 16)
- Conduct continuous risk-based screening for sanctions compliance; report blocked assets to OFAC/UIF
- First annual compliance audit cycle began 1 January 2026
- Report crypto holdings for tax purposes under Law 27,743 (blanqueo); declare gains on Ganancias and Bienes Personales forms
Key Restrictions
- Must incorporate a local entity (SA or SRL/LLC) with at least 1 local director and 2 shareholders
- Minimum net worth of $5,000–$50,000 depending on license classification (half in cash for new applicants; $50,000 for money transmitters)
- Registration thresholds apply: mandatory if monthly volumes exceed ~35,000 UVA (~$29,246)
- Virtual office is permitted but local presence is required
- Unregistered VASPs cannot operate; unregistered platforms face enforcement (e.g., Polymarket blocked, CoinX banned)
- BCRA bank prohibition on crypto trading/custody still in effect as of early 2026, though easing anticipated
Key Risks
- Enforcement precedent: Polymarket (nationwide block), CoinX (ban for unregistered/Ponzi-like operations), $LIBRA scandal (market manipulation/rug pull allegations)
- Coinbase suspended ARS-to-USDC operations after less than one year — regulatory uncertainty remains a practical risk
- Regulatory framework only fully enforceable since 31 December 2025; some rules (e.g., CNV Resolution 1025 draft) still in consultation phase
- Tax obligations complex: worldwide income for residents, crypto-to-crypto trades taxable, 5-15% rates, AFIP enforcement
- FATF Travel Rule fully live — fragmented tech solutions globally create compliance challenges
- Penalties: UIF fines up to ~ARS 13.5M, license revocation, criminal charges under Penal Code Arts. 303-309
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.
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).
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)
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.
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.
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).
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.
Law 27,739 (2024): Integrates VASPs into AML/KYC framework; registration with CNV required.
Rates: 5-15%, depending on declaration timing, currency (ARS vs. foreign), and year (e.g., 5% for pre-March 2024 declarations; 15% in 2025).
Crypto-to-crypto trades and DeFi disposals count as taxable events.
Regulator: Buenos Aires Court (Judge Susana Parada)
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.
Regulator: National Securities Commission (CNV) under Law 27,739 (passed March 2024)
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — an on-shore VASP is permitted in Argentina but must (a) incorporate a local entity, (b) register with the CNV VASP/PSAV registry and UIF, (c) meet minimum net worth of $5,000–$50,000, and (d) comply with full AML/KYC/Travel Rule obligations under CNV and UIF oversight.
Questions this verdict aims to answer
- What license(s) are required to operate locally?
- What capital, governance, and reporting obligations apply?
- What is the application process and timeline?