Self-custodial wallet / non-custodial software in Argentina
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet 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
- Registration with CNV's VASP registry (PSAV registry) under Law 27,739 and CNV General Resolution 994/2024
- Registration with UIF under UIF Resolution 49/2024 for AML compliance
- Implementation of strict KYC procedures and continuous transaction monitoring
- Continuous risk-based screening of customers, wallets, and transactions against OFAC SDN, EU/UN, OFSI, and Argentina's RePET sanctions lists
- Reporting of suspicious activities to UIF within 150 days
- Appointment of a mandatory compliance officer
- Reporting blocked assets to OFAC/UIF
- Compliance with FATF-aligned AML/CTF standards — Argentina is on FATF Travel-Rule Monitoring List as 'Fully cooperative'
- First annual compliance audit cycle starting 1 January 2026; obligations fully enforceable since 31 December 2025
Key Restrictions
- Must incorporate a local entity (SA or SRL/LLC) with 1 local director and 2 shareholders; virtual office allowed
- Must register with CNV if monthly volumes exceed 35,000 UVA (~$29,246)
- Net worth requirement of $5,000–$50,000 depending on classification (half in cash for new applicants)
- Full legal framework took effect 31 December 2025; obligations are live and enforced in 2026
- CNV Resolution No. 1058/2025 mandates transparency and compliance updates
Key Risks
- Ambiguity on whether purely self-custodial software publishers (who never hold user keys or funds) are caught by the VASP definition under Law 27,739 and CNV Resolution 994/2024
- If classified as a VASP, the publisher must implement KYC — which may be technically infeasible for a non-custodial tool that does not collect user data
- Enforcement precedent (Polymarket blocked nationwide, Coinbase suspended operations, CoinX banned) shows aggressive regulator posture toward unregistered crypto services
- Argentina's BCRA is still reviewing lifting the bank prohibition on crypto; regulatory direction could shift
- Tax obligations under Law 27,743 (declaration of crypto holdings) and AFIP enforcement create parallel reporting exposure
- UIF fines up to ~ARS 13.5M (~$13.5K USD equivalent), license revocation, and criminal charges possible 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).
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.
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).
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.
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.
Regulator: National Securities Commission (CNV) under Law 27,739 (passed March 2024)
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: 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: 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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- low
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — purely self-custodial wallet software publishers face uncertainty under Argentina's VASP regime because the definition in Law 27,739/CNV Resolution 994/2024 may capture any entity targeting Argentine users with crypto services, and if classified as a VASP, the publisher would need to register with CNV, incorporate locally, meet net-worth thresholds, and implement KYC/AML obligations that are technically difficult to fulfill without custody of user funds.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?