Remote VASP serving residents in Argentina
Foreign-incorporated entity that offers exchange, custody, or transfer services to residents of a jurisdiction without establishing a local entity or office.
Remote VASP 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
- Mandatory registration with CNV's VASP registry (PSAV) — Law 27,739 and CNV General Resolution 994/2024
- Registration with UIF for AML compliance — UIF Resolution 49/2024
- Strict KYC procedures with continuous risk-based screening of customers, wallets, and transactions against OFAC SDN, EU/UN, and Argentina's RePET sanctions lists (Law 25,246, UIF Resolution 242/2023)
- Suspicious Activity Reports (SARs) to UIF within 150 days
- Travel Rule compliance: collect, transmit, and retain originator/beneficiary information for in-scope crypto-asset transfers (fully enforceable since 31 Dec 2025, aligned with FATF Recommendation 16)
- Report blocked assets to OFAC/UIF; no dealing with sanctioned entities or crypto from sanctioned sources
- Continuous transaction monitoring with risk-based approach
- Appointment of a mandatory compliance officer
- First annual compliance audit cycle started 1 January 2026
- Tax obligations enforced by AFIP including capital gains reporting; Law 27,743 requires users to declare crypto holdings
- Minimum net worth of $5,000–$50,000 (classification-dependent) for license applicants; half in cash for new applicants
Key Restrictions
- Must incorporate a local entity (SA or SRL/LLC) in Argentina with 1 local director and 2 shareholders; virtual office allowed
- Unregistered VASPs cannot legally operate — foreign entities targeting Argentine users are captured under the regime
- Registration deadlines: foreign entities by 1 September 2025 (CNV Resolution 1058/2025); framework fully enforceable from 31 Dec 2025
- Monthly volume threshold of 35,000 UVA (~$29,246) triggers mandatory registration
- No specific protocols (e.g., interoperability standards) detailed for Travel Rule compliance — fragmented tech landscape
- BCRA is reviewing plans to lift the bank prohibition on crypto trading/custody — uncertain near-term evolution
Key Risks
- Enforcement precedent exists for unregistered platforms: CoinX banned (Ponzi-like operations), Polymarket blocked (unauthorized betting), Coinbase suspended ARS-USDC trading after regulatory pressure
- Unregistered operators face nationwide access blocks, ISP blocking, app store removal, and potential criminal liability
- UIF fines up to ~ARS 13.5M (~$13.5K USD equivalent), license revocation, and criminal charges under Penal Code Arts. 303-309 for terrorism financing
- FATF 'Updated Travel-Rule Monitoring List' with Argentina as 'Fully cooperative' — indicates active cross-border enforcement risk
- Political risk: President Milei's $LIBRA rug-pull scandal demonstrates high-profile enforcement and reputational exposure for crypto operations
- Tax regularization (Law 27,743) and AFIP enforcement creates transparency risk for remote operators' client base
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.
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)
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.
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
Compliance with CNV Resolution 994/2024, which established the VASP registration framework
Reporting of suspicious activities to the Financial Information Unit (UIF) within 150 days
Implementation of strict Know Your Customer (KYC) procedures and continuous transaction monitoring
CNV Resolution No. 1058/2025 updates emphasize transparency and compliance.
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).
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.
Adopted through Law 27.739 (March 2024), which defines PSAVs, followed by phased registration in 2025 and UIF Resolution 49/2024.
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.
Applies to registered PSAVs (domestic and foreign VASPs operating in or targeting Argentina users), post-mandatory CNV registration.
Strict on unhosted wallets and inbound cross-border transfers.
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.
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.
Legal basis: Law 25,246 (AML), UIF Resolution 94/2023 for VASPs; RePET under National Law 26,268.
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 — a foreign-incorporated VASP may serve Argentine residents only after incorporating a local entity (SA or SRL/LLC), registering with the CNV VASP registry and UIF for AML compliance, meeting capital thresholds ($5K–$50K), and adhering to comprehensive AML/KYC, sanctions screening, Travel Rule, and suspicious activity reporting obligations under the fully enforceable framework effective 31 December 2025.
Questions this verdict aims to answer
- May a non-resident provider serve residents from abroad?
- Does cross-border service trigger licensing, registration, or AML obligations?
- What enforcement risk exists for unlicensed remote operators?