Centralized exchange in Paraguay
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Paraguay 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 SEPRELAD as a VASP under Resolution No. 222/2022 and Resolution No. 24/2023
- Appointment of a qualified Compliance Officer responsible for AML/CFT compliance
- Implementation of comprehensive AML/CFT policies and procedures including risk assessment, CDD, EDD for high-risk customers, and ongoing monitoring
- Customer identification and verification (KYC) for natural and legal persons
- Transaction monitoring for suspicious patterns and activities
- Reporting of Suspicious Activity Reports (SARs) to SEPRELAD
- Employee training on AML/CFT obligations
- Record keeping of customer identification data and transaction records for at least 5 years
- Maintenance of a physical registered office in Paraguay
- Robust technological infrastructure and cybersecurity protocols for data protection and secure record-keeping
Key Restrictions
- Must obtain a general operating license from the Ministry of Industry and Commerce (MIC) under Law No. 6995/2022 to operate as a crypto asset commercialization business
- Must register with SEPRELAD as a VASP and comply with AML/CFT resolutions (No. 222/2022 and No. 24/2023)
- Must be established as a legal entity (corporation or LLC) duly registered in Paraguay with a physical registered office
- Cryptocurrencies are not recognized as legal tender or financial instruments by the BCP — no banking or financial regulatory framework applies
- No specific crypto custody license exists; custody falls under the general MIC operating license with no explicit segregation, cold storage, or insurance requirements
- Travel rule obligations are implied via FATF Recommendation 15 adherence through GAFILAT membership, but no domestic-specific travel rule regulation is detailed in the provided facts
Key Risks
- Regulatory ambiguity — Law 6995/2022 provides a general framework but secondary regulations from MIC detailing operational standards for exchanges and custody are not yet published
- No dedicated financial regulator (BCP) oversight for crypto exchanges — MIC and SEPRELAD share responsibility, creating potential supervisory gaps
- No explicit asset segregation, cold storage, insurance, or capital adequacy requirements for user funds in custody
- Enforcement focus to date has been on illegal crypto mining (electricity theft), not on VASP compliance — risk of future enforcement actions as SEPRELAD framework matures
- Travel rule requirements are ambiguous — no domestic implementation guidance, only FATF/GAFILAT-level obligations
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Law No. 6995/2022: Ley que crea el marco regulatorio para la explotación comercial de la minería, comercialización y la industrialización de activos digitales criptoactivos (Law creating the regulatory framework for the commercial exploitation of mining, commercialization, and industrialization of crypto digital assets).
Ministry of Industry and Commerce (MIC): This is the primary regulatory body designated by Law 6995/2022 for issuing operating licenses and overseeing the activities related to the commercial exploitation, mining, commercialization, and industrialization of crypto assets.
General Operating License: Law 6995/2022 mandates that any company engaged in the "commercial exploitation, mining, commercialization and industrialization of crypto assets" must obtain an operating license from the Ministry of Industry and Commerce (MIC).
SEPRELAD (Secretaría de Prevención de Lavado de Dinero o Bienes): This is the key regulatory body for AML/CFT compliance for virtual assets. SEPRELAD defines Virtual Asset Service Providers (VASPs) and sets forth their obligations.
Resolution No. 222/2022: This resolution from SEPRELAD specifically established guidelines for the prevention of money laundering and terrorism financing for Virtual Asset Service Providers. It defines what constitutes a VASP and outlines their obligations.
Resolution No. 24/2023: This resolution modified certain aspects of Resolution No. 222/2022, particularly detailing reporting requirements for VASPs.
FATF Recommendations: Paraguay, as a member of GAFILAT (the regional FATF-style body), adheres to FATF recommendations, which include guidance on virtual assets and VASPs (Recommendation 15 and its Interpretive Note).
Exchanges (Virtual Asset Exchange Providers): Entities that conduct the exchange between virtual assets and fiat currencies, or between one or more forms of virtual assets, are considered VASPs.
Custody Providers (Virtual Asset Custody Providers): Entities that provide safekeeping services for virtual assets or instruments enabling control over virtual assets are considered VASPs.
AML/KYC (Anti-Money Laundering / Know Your Customer): This is the core requirement.
Robust Policies and Procedures: Implementation of comprehensive AML/CFT policies and procedures, including risk assessment, customer due diligence (CDD), enhanced due diligence (EDD) for high-risk customers, and ongoing monitoring.
Customer Identification and Verification: Collecting and verifying identity information for natural and legal persons (KYC).
Transaction Monitoring: Monitoring transactions for suspicious patterns and activities.
Suspicious Activity Reports (SARs): Reporting suspicious transactions to SEPRELAD.
Compliance Officer: Appointment of a qualified and designated Compliance Officer responsible for AML/CFT compliance.
Employee Training: Regular training for employees on AML/CFT obligations.
Record Keeping: Maintaining records of customer identification data and transactions for the prescribed period (usually 5 years).
Legal Entity: The VASP must be established as a legal entity (e.g., corporation or limited liability company) duly registered in Paraguay.
Registered Office: Maintenance of a physical registered office in Paraguay.
There is no specific "crypto custody license" distinct from the general operating license for crypto businesses established by Law 6995/2022, nor is there a dedicated financial regulator (like the BCP) overseeing crypto custody in the same way they do for traditional financial institutions.
No Explicit Requirements: The current legislation does not explicitly mandate insurance coverage or bonding requirements specifically for crypto asset custodians.
No Explicit Mandates: There are no explicit regulatory mandates in Paraguay for the use of cold storage (offline storage) for digital assets under custody. The law does not prescribe specific technical security measures for asset storage.
No Specific Definition: Paraguay's existing legislation does not provide a specific definition for a "qualified custodian" in the context of digital assets, similar to those found in U.S. or European financial regulations.
General commercial and consumer protection laws would apply, but there are no specific crypto-focused requirements for asset segregation.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a centralized exchange may operate in Paraguay by obtaining a general operating license from the Ministry of Industry and Commerce (MIC) under Law 6995/2022 and registering as a VASP with SEPRELAD for AML/CFT compliance, but the regulatory framework lacks specific rules on custody segregation, travel-rule implementation, capital adequacy, and insurance, creating operational uncertainty.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?