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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.

Conditional AI-Generated · Unreviewed

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).

licensing 100% confidence

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

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 100% confidence

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

licensing 93% confidence

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.

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.

licensing 70% confidence

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.

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 20% confidence

Supporting resolutions: CNV General Resolution 1025 (October 2024 draft on VASP rules); CNV Resolution 1058/2025 (mandatory registration deadlines, net worth, AML standards).

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 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.

enforcement 20% confidence

Regulator: National Securities Commission (CNV) under Law 27,739 (passed March 2024)

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: 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.

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.

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?