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Stablecoin issuer / redeemer in Argentina

Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.

Conditional AI-Generated · Unreviewed

Stablecoin issuer 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

  • Register with CNV VASP registry per Law 27,739 and CNV Resolution 994/2024
  • Register with UIF as a Sujeto Obligado per UIF Resolution 49/2024
  • Implement robust KYC procedures and continuous transaction monitoring
  • Report suspicious activities to UIF within 150 days
  • Conduct continuous risk-based screening of customers, wallets, and transactions against OFAC SDN, EU/UN sanctions lists, and Argentina's RePET list
  • Report blocked assets to UIF
  • Appoint a mandatory compliance officer
  • Comply with FATF Travel Rule obligations (Argentina is on FATF Travel Rule Monitoring List as fully cooperative)
  • Submit annual compliance audit (first cycle starting 1 Jan 2026)
  • Declare crypto holdings for tax purposes per Law 27,743 (blanqueo/asset regularization)

Key Restrictions

  • Stablecoin issuance likely requires classification as a PSAV (Virtual Asset Service Provider) and CNV registration — no separate e-money or banking license framework identified for stablecoins specifically
  • Local entity required: must incorporate as SA or SRL with 1 local director and 2 shareholders
  • Minimum net worth of $5,000–$50,000 (classification-dependent) — may be too low for stablecoin reserve adequacy; unclear if higher reserve requirements apply
  • BCRA (central bank) prohibition on banks offering crypto services still in place, though easing is anticipated — restricts banking partner options
  • Foreign-issued stablecoins (e.g., USDC, USDT) may be permissible for use locally if operators are CNV-registered, but no explicit framework governing issuance vs. distribution of third-party stablecoins exists
  • No specific reserve composition, segregation, or audit rules for stablecoin issuers are detailed in available framework — this is a gap/risk

Key Risks

  • No dedicated stablecoin or e-money framework — issuer may be shoehorned into generic VASP registration without reserve/redemption-specific rules
  • Reserve segregation, composition (e.g., 1:1 backing), and audit requirements are legally undefined for stablecoin issuers
  • Redemption rights for holders are not codified in the VASP regulatory framework
  • BCRA's bank prohibition on crypto services limits ability to maintain reserve accounts with regulated banks
  • Regulatory ambiguity between stablecoins as virtual assets vs. potential securities classification could create reclassification risk
  • Tax treatment of stablecoin issuance/redemption (not just trading) is unclear under existing crypto-asset tax rules
  • UIF fines up to ~ARS 13.5M, plus license revocation and criminal liability for AML failures

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 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 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 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 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

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 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.

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 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 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.

tax 20% confidence

Law 27,739 (2024): Integrates VASPs into AML/KYC framework; registration with CNV required.

tax 95% confidence

Law 27.743: Mandatory crypto declaration for tax/regularization.

tax 85% confidence

Businesses/VASPs: Register with Comisión Nacional de Valores (CNV) per Law 27.739 (2024); comply with AML/CFT (FATF-aligned). Declare under asset regularization (blanqueo, Law 27.743).

aml 20% confidence

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.

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 — stablecoin issuance in Argentina is possible via CNV VASP registration, but the framework lacks dedicated stablecoin-specific rules on e-money licensing, reserve segregation, composition, audit, and redemption rights; foreign-issued stablecoins likely usable locally via registered VASPs, but legal clarity is low.

Questions this verdict aims to answer

  • What e-money or banking license is required to issue?
  • What reserve composition, segregation, and audit rules apply?
  • What redemption rights must be granted to holders?
  • Are foreign-issued stablecoins permitted for use locally?