Why Choose Argentina for Crypto Licensing?
Argentina suits operators with a genuine Argentine market: the country ranked 20th in Chainalysis’s 2025 Global Crypto Adoption Index and second in Latin America by crypto value received, behind Brazil, driven by persistent inflation and capital-control pressures that push retail users toward stablecoins.[20][21] Since March 2024, virtual asset service providers are formally regulated. Law 27.739 made PSAVs obligated subjects under the anti-money-laundering framework and ordered the CNV to create a registry; CNV General Resolution 1058/2025 then set a substantive registration, net-worth, and supervision regime.[1][4]
One of Latin America’s Largest Crypto Markets
Argentina’s crypto demand is structural, not speculative. Years of high inflation and currency restrictions have made dollar-pegged stablecoins a practical savings and settlement tool for ordinary households and businesses. That demand is why a PSAV registration with a real Argentine user base is a commercial asset rather than a paper credential. The flip side is regulatory seriousness: the CNV treats PSAVs as supervised participants, with monthly and annual reporting, external system audits, and minimum-net-worth tests, closer to a securities-intermediary regime than a light-touch offshore register.[4]
A Mandatory Registration Regime, Not a Discretionary Licence
Argentina does not issue a discretionary crypto licence. It runs a registry of general application: any natural or legal person that, as a business, exchanges, transfers, custodies, administers, or provides financial services around virtual assets to Argentine residents must register as a PSAV.[5] The reach is broad. CNV General Resolution 994/2024 captured foreign providers that direct services to Argentine residents through websites, social media, local-funds collection, or targeted offers.
Individuals whose covered transactions total no more than 35,000 UVA in a calendar month are exempt from PSAV registration. The threshold includes exactly 35,000 UVA and uses the UVA value on the last day of that month. Legal entities have no small-volume exemption.[4]
Separate exclusions cover dealing solely for one's own account, accepting or delivering virtual assets for one's own goods or services, decentralised protocols without an identifiable service provider, and providers limited to self-custody wallets. These are activity exclusions, not a corporate-platform exemption. A provider operating inside the registration perimeter without registration risks court-ordered blocking in Argentina.[3][4]
FATF-Aligned, Off the Grey List
The PSAV framework was built in direct response to FATF Recommendation 15 on virtual assets. The joint FATF/GAFILAT mutual evaluation, with an on-site visit in March 2024, was adopted at the October 2024 plenary, and FATF did not grey-list Argentina, but placed it in enhanced follow-up.[6] For correspondent-banking and counterparty-diligence conversations, that combination matters: a regulated PSAV in a jurisdiction that is off the grey list reads very differently from an unregulated operator in a jurisdiction with an open Recommendation 15 gap.
Local Entity Required, Offshore Structuring Closed
Argentina is not an offshore wrapper. CNV General Resolution 1058/2025 admits a legal person only as an Argentine S.A. or S.R.L. under Company Law 19.550 or as a foreign company registered under Article 118 of that law, excludes the simplified S.A.S. form, and bars legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list.[4] Foreign providers therefore enter through a branch registered under Article 118 or a local company (foreign shareholding via Article 123).
Argentina suits operators committed to the local market rather than those seeking pure tax-driven offshore structuring; for the committed operator, Jagelski & Partners scopes the route in writing and introduces an independent specialist for the local entity, registration, and banking.
Regulatory Framework
Crypto is legal in Argentina but is not legal tender; only the Argentine peso has legal-tender status. Virtual assets and their service providers are regulated under a layered framework: Law 27.739 (an AML reform), UIF Resolution 49/2024 (the financial-intelligence obligations), and CNV General Resolutions 994/2024 and 1058/2025 (the registry and operating regime). The CNV is the registration and prudential supervisor; the UIF is the AML financial-intelligence authority.[1][2][4]
What “PSAV registration” means in Argentina
PSAV registration is mandatory inscription in the CNV’s Registro de Proveedores de Servicios de Activos Virtuales. It captures any natural or legal person that, as a business, exchanges, transfers, custodies, administers, or provides financial services around virtual assets to Argentine residents.[5] Registration is not a one-off certificate: a registered PSAV is a supervised participant with minimum-net-worth, segregation-of-client-asset, cybersecurity, audit, AML, and periodic-reporting obligations under CNV RG 1058/2025. Human persons resident in Argentina may register only for the two exchange categories; all other activities require a legal entity: an Argentine S.A. or S.R.L., or a foreign company registered under Article 118.[4]
Regulatory History
Argentina’s crypto rules moved from absence to a full regime in roughly a year. Before 2024 there was no dedicated PSAV framework; crypto trading and holding were lawful but unsupervised, taxed under general rules. The catalyst was the FATF/GAFILAT mutual evaluation cycle and FATF Recommendation 15 on virtual assets, which pressed Argentina to bring VASPs into the AML perimeter ahead of the October 2024 plenary.[6]
Law 27.739, published on , amended anti-money-laundering Law 25.246 to define and capture PSAVs as obligated subjects and to mandate a CNV registry.[1] On two instruments published together: CNV General Resolution 994/2024 created the PSAV registry under Article 4 bis of Law 25.246, and UIF Resolution 49/2024 set the risk-based AML obligations binding on PSAVs.[3][2]
The substantive regime arrived with CNV General Resolution 1058/2025, published in the Boletín Oficial on and in force from .[4][5] RG 1058/2025 added the five-category structure, minimum-net-worth requirements expressed in US dollars, the local-entity rule, segregation of client assets, cybersecurity governance, external audits, and staged compliance deadlines. From , inscription and cancellation requests are filed exclusively through the Trámites a Distancia (TAD) platform.[5]
Recent Regulatory Developments
- : CNV General Resolution 1058/2025 published.[4] Established the five PSAV categories, minimum net worth of USD 35,000 to 150,000 by category (halved for Categories 1 to 4 below USD 2,500,000 in 12-month volume), the S.A. or S.R.L. (or Article 118 branch or other permanent representation) requirement for legal persons, the S.A.S. exclusion, the bar on legal persons from jurisdictions on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list, asset segregation, cybersecurity, external audits, and staged deadlines. In force from .
- : registration moves to the TAD platform.[5] All PSAV inscription and cancellation requests filed exclusively through Trámites a Distancia.
- October 2024: FATF plenary adopts Argentina’s mutual evaluation.[6] Argentina was placed in enhanced follow-up, distinct from grey-list increased monitoring; the report identified outcome shortcomings but recognised strengthened AML laws and inter-agency coordination.
- : CNV RG 994/2024 and UIF Resolution 49/2024 published.[3][2] Created the registry under Law 25.246 Article 4 bis and set risk-based AML obligations for PSAVs.
- : Law 27.739 published.[1] Amended AML Law 25.246, brought PSAVs into the obligated-subject perimeter, and mandated the CNV registry.
Regulatory Overlap
Four overlapping regimes shape the Argentine compliance picture:
- Law 25.246 (AML/CFT, as amended by Law 27.739). Defines PSAVs as obligated subjects and mandates the CNV registry under Article 4 bis.[1]
- UIF Resolution 49/2024. Sets the risk-based AML/CFT system imposed on PSAVs: client, product, channel, and geographic risk factors; enhanced due diligence for FATF-listed jurisdictions; and the Travel Rule logic for transfers lacking originator or beneficiary information.[2]
- CNV General Resolution 1058/2025. The operating regime: categories, net worth, local-entity rule, segregation, cybersecurity, audits, officers, and reporting.[4]
- Company Law 19.550 and tax law. Governs the S.A. or S.R.L. form, branch registration (Articles 118 and 123), corporate income tax, and the provincial Ingresos Brutos turnover tax on trading.[7]
PSAV Categories and Activities Covered
CNV General Resolution 1058/2025 organises PSAV registration around five activity categories, each carrying its own minimum net worth and, for some, its own eligibility rule. A provider registers for the categories that match its actual activities and meets the highest applicable net-worth threshold. The categories track FATF Recommendation 15’s VASP definition closely.[4]
The Five PSAV Categories
The categories defined in Article 8 of CNV RG 1058/2025, with the minimum net worth set in Article 9, are:[4]
- Category 1, exchange between virtual assets and legal-tender currencies. Fiat on-ramp and off-ramp, centralised exchange order books pairing crypto with pesos or dollars, OTC desks. Minimum net worth USD 150,000.
- Category 2, exchange between one or more forms of virtual assets. Crypto-to-crypto trading, token-pair markets. Minimum net worth USD 150,000.
- Category 3, transfer of virtual assets. Wallet-to-wallet transfer services, crypto payment processors moving assets between counterparties. Minimum net worth USD 75,000.
- Category 4, custody or administration of virtual assets, or of instruments enabling control of them. Custodial wallets, key-management services, exchange custody arms. Minimum net worth USD 150,000.
- Category 5, participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset. Primary-issuance support, token-sale platforms. Minimum net worth USD 35,000.
The minimum net worth halves for Categories 1 to 4 (to USD 75,000, 75,000, 37,500 and 75,000) where the provider is under USD 2,500,000 over the prior 12 months, measured on transacted volume for Categories 1 to 3 and on custodied volume for Category 4.
Article 9 omits Category 5 from the reduction paragraph, so its USD 35,000 applies at any volume. Client virtual assets are kept segregated and cannot be counted toward the net-worth requirement; fiduciary holdings appear as off-balance-sheet memorandum accounts.[4]
Who May Operate Which Category
Article 8 limits human persons to Categories 1 and 2 (the two exchange activities). Categories 3, 4, and 5 require a legal person: an Argentine S.A. or S.R.L., or a foreign legal person registered under Article 118 of Company Law 19.550 through a branch, seat, or other permanent representation.[4] The exchange-only carve-out for individuals is narrow and rarely fits a commercial platform.
Activity Restrictions Inside the Regime
RG 1058/2025 also restricts what a registered PSAV may offer. Article 37 limits the listing of newly launched assets: virtual assets whose launch is less than 90 days old may be offered only with a prominent risk warning highlighting elevated volatility and loss-of-principal risk.[4] The resolution separately prohibits any offering or intermediation that would amount to a public offering of virtual assets that qualify as securities (valores negociables) without separate CNV authorisation. These guardrails keep the PSAV registry distinct from Argentina’s public-securities-offering regime.
Requirements
Argentina’s PSAV requirements are substantive, not nominal. CNV General Resolution 1058/2025 mandates a local S.A. or S.R.L. or an Article 118 branch or other permanent representation for legal persons, a minimum net worth tied to the registered categories, segregation of client assets, a designated compliance officer and a public-relations officer, a documented cybersecurity programme, an annual external system audit, and a UIF-compliant AML system. There is no offshore-only path.[4]
Argentina PSAV Requirements Table
| Requirement | Standard |
|---|---|
| Entity types permitted | Sociedad Anónima (S.A.) or Sociedad de Responsabilidad Limitada (S.R.L.) under Company Law 19.550, or a foreign company registered under Article 118; S.A.S. excluded[4] |
| Human persons | Residents of Argentina, for Category 1 and Category 2 only (the exchange activities); other categories require a legal entity |
| Foreign providers | Branch under Article 118 of Law 19.550, or a local company (foreign shareholding via Article 123); deadline was |
| Barred jurisdictions | Legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list cannot register[4] |
| Minimum net worth | USD 150,000 (Cat. 1, 2, 4); USD 75,000 (Cat. 3); USD 35,000 (Cat. 5); Cat. 1–4 halved below USD 2,500,000 in 12-month volume[4] |
| Client-asset segregation | Yes; client virtual assets kept separate from the PSAV’s own assets and excluded from net worth (Article 16)[4] |
| Compliance officer | Designated Responsable de Cumplimiento Regulatorio y Control Interno, who may be a board member or local representative and otherwise reports directly to the board or, for an Article 118 branch, to its local representatives; annual report within 70 calendar days of the calendar year-end[4] |
| Public-relations officer | Designated Responsable de Relaciones con el Público for complaint handling |
| Cybersecurity | Risk-based governance, identification, protection, detection, and response-and-recovery protocols (Article 13)[4] |
| External audit | Annual system audit by certified IT professionals, due 70 calendar days after the end of the calendar year (Article 20)[4] |
| AML/CFT | UIF-compliant risk-based system per UIF Resolution 49/2024; KYC, sanctions screening, Travel Rule logic, suspicious-transaction reporting[2] |
| Periodic reporting | Monthly transaction volume and client count (10 days after month-end, from October 2025); audited financial statements and compliance report annually |
| Registration platform | Trámites a Distancia (TAD) exclusively, from [5] |
Fit-and-Proper and Officer Requirements
The CNV regime is approval-and-supervision based, not a passive register. Every applicant designates a compliance officer and a public-relations officer for complaint handling, and maintains procedure manuals, a code of conduct, security policies, and complaint procedures. The compliance officer may be a board member or local representative; otherwise the officer reports directly to the board or, for an Article 118 branch, to its local representatives.[4] Directors and beneficial owners are screened for AML purposes under UIF Resolution 49/2024, including sanctions screening and enhanced due diligence where exposure to FATF-listed jurisdictions arises. The CNV reviews the documentation set rather than rubber-stamping the filing.
Local Presence and the Offshore Bar
The binding local-presence requirement is the Argentine operating entity itself. A PSAV that is a legal person must be an S.A. or S.R.L. incorporated under Company Law 19.550, with the S.A.S. form excluded, or a foreign company registered under Article 118 as a branch or other permanent representation. A foreign provider directing services to Argentine residents has two routes only: a branch, seat or other permanent representation registered under Article 118 of Law 19.550, or a local company, in which case foreign shareholding is registered under Article 123.[4]
Legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list cannot register.[4] The original deadline for foreign providers to put a local footprint in place was .
AML/CFT and Travel Rule
The binding AML/CFT regime is UIF Resolution 49/2024, which requires a risk-based system addressing client, product, channel, and geographic risk, with enhanced due diligence for relationships and transactions involving FATF-identified jurisdictions.[2] That system spans KYC and customer due diligence, beneficial-ownership identification, sanctions screening, ongoing transaction monitoring, and suspicious-transaction reporting to the UIF.
Travel Rule logic is built into the UIF framework: a PSAV must determine the cases in which it is authorised not to complete, or to suspend, a virtual-asset transfer that lacks the required originator or beneficiary information.[2] The practical effect mirrors FATF Recommendation 16: counterparty information travels with cross-border transfers, and incomplete transfers can be held.
The common mistake is treating a generic AML policy from another jurisdiction as Argentina-compliant. The UIF expects policies calibrated to Resolution 49/2024 and to the operator’s actual model. Generic templates trigger rework at inscription review and again at banking onboarding.
Registration Process
The PSAV set-up runs five stages from pre-incorporation to operational launch. Incorporating the Argentine S.A. or S.R.L. with the Inspección General de Justicia (IGJ) runs roughly 4 to 10 weeks; assembling the AML, cybersecurity, net-worth, and corporate documentation runs 6 to 10 weeks of specialist work; the PSAV inscription is then filed through the TAD platform and reviewed by the CNV. Total realistic timeline is 3 to 6 months to a complete CNV filing, plus the CNV review, which RG 1058/2025 does not time-limit,[4] with banking and exchange-account access the most variable element.
Application language: Spanish. Filings with the IGJ, the CNV, and the tax authority (ARCA, formerly AFIP) are conducted in Spanish through the IGJ, CNV, and TAD platforms respectively. Foreign documents require certified Spanish translation and apostille or legalisation.
Pre-application engagement: The CNV does not run formal pre-application meetings for PSAV applicants. The practical route is to work through an Argentine firm experienced in CNV filings, which screens the documentation set before the TAD submission to reduce review iterations.
Visual Timeline
Entity Formation
Incorporate an Argentine S.A. or S.R.L. with the IGJ (or the relevant provincial registry), or register a branch under Article 118 of Company Law 19.550 for a foreign provider. The S.A.S. form is excluded for PSAV use. See the full Argentina company formation guide → for the SA-or-SRL choice, costs, and the remote-formation route.
Tax and Corporate Registration
Obtain the tax identification (CUIT) with ARCA, register for the relevant provincial Ingresos Brutos turnover tax, and complete corporate-book and beneficial-owner registrations.
Compliance Documentation
Draft the UIF-calibrated AML/CFT programme, cybersecurity policy, client-asset segregation procedures, complaint procedures, code of conduct, and the net-worth evidence. Appoint the compliance officer and the public-relations officer. This is the most time-intensive stage.
PSAV Inscription via TAD
File the PSAV inscription request through the Trámites a Distancia (TAD) platform with the full documentation set. The CNV reviews categories, net worth, AML, and cybersecurity before inscription in the Registro de PSAV.
Banking and Operational Launch
Open banking and settlement accounts and begin the monthly CNV reporting regime (transaction volume and client count, due 10 days after month-end). Banking access is the most variable element and should run in parallel with earlier stages.
The compliance documentation is the most time-intensive component of any Argentine PSAV set-up: 6 to 10 weeks of specialist work that generic templates cannot shortcut. The CNV review focuses on whether the AML and cybersecurity programmes are genuinely tailored to the applicant’s model and categories, and on whether the net-worth evidence is sound. Map the documentation set early, since the CNV treats it as substantive rather than formal.
Required Documents
Argentine corporate and CNV practice works from a standardised set of corporate, personal, and compliance documentation. The CNV reviews the substance of the AML and cybersecurity programmes, the net-worth evidence, and the corporate chain, not just a checklist. The depth lives in the underlying instruments, calibrated to UIF Resolution 49/2024 and CNV RG 1058/2025.[2][4]
Corporate Documents
- Constitutive instrument and bylaws (estatuto) of the Argentine S.A. or S.R.L., registered with the IGJ or the relevant provincial registry, updated to current text.
- Branch registration documents for foreign providers registering under Article 118 of Company Law 19.550, or the Article 123 participation filing for a local subsidiary.
- Tax identification (CUIT) and proof of registration with ARCA and the relevant provincial revenue authority.
- Details of directors, company secretary, and shareholders, with the corporate ownership chain to ultimate beneficial owners.
- Proof of registered office (lease or ownership) and banking details.
Personal Documents (all directors, officers, beneficial owners)
- Identity document or passport for each director, officer, signatory, and beneficial owner.
- Criminal-record certificate evidencing no relevant convictions, from the country of residence, apostilled or legalised where issued abroad.
- Tax-compliance certificate evidencing no unpaid taxes, for the entity and key individuals.
- CV / professional resume documenting relevant experience for officers.
- Proof of address (utility bill or bank statement, recent).
Compliance Documentation
The compliance documentation is the most heavily scrutinised component of any Argentine PSAV set-up. Each document needs to be bespoke and Argentina-specific, calibrated to UIF Resolution 49/2024 and CNV RG 1058/2025 rather than ported from another jurisdiction, and to reflect the applicant’s actual categories, business model, risk profile, and operational structure.
- AML/CFT Policy Manual: Operational manual covering CDD, risk classification, transaction monitoring, sanctions screening, and suspicious-transaction reporting, calibrated to UIF Resolution 49/2024.
What it covers
The AML/CFT Policy Manual is the operational backbone of any PSAV inscription. It identifies the obligated subject under Law 25.246 as amended by Law 27.739, names the compliance officer, and describes the risk-based methodology required by UIF Resolution 49/2024, addressing client, product, channel, and geographic risk.
A manual that reads as a generic template ported from another Latin American jurisdiction is the single most common cause of review delay; it has to align with the firm’s actual categories and operational reality.[2]
- Enterprise-Wide Risk Assessment: ML/TF, operational, technology, and jurisdictional risk identification, with risk-scoring methodology and mitigation matrix.
What it covers
The Enterprise-Wide Risk Assessment documents the firm’s identification and assessment of ML/TF, technology, and jurisdictional risks. UIF Resolution 49/2024 requires a risk-based approach considering minimum risk factors tied to clients, products, and services, distribution channels, and geographic areas, with enhanced measures for FATF-identified jurisdictions. Argentina-specific risk inputs (counterparty geography, customer profile, product complexity) need to be reflected. The assessment underpins the compliance officer’s annual report.[2]
- Sanctions Screening Procedures: Procedural document covering OFAC SDN, EU consolidated list, UN Security Council, Argentine designated-persons lists, and screening-frequency protocols.
What it covers
Argentine PSAVs screen against multiple sanctions lists: OFAC SDN, the EU consolidated financial-sanctions list, UN Security Council sanctions lists, and Argentine designated-persons lists. Screening is required at onboarding, at counterparty designation, and on a recurring risk-based schedule, typically daily for high-risk segments. Examiners commonly request evidence of screening hits, false-positive triage records, and escalation logs.
- KYC and Client Onboarding (incl. KYB): Customer due diligence, enhanced due diligence for PEPs and high-risk profiles, beneficial-ownership identification, document-collection, and verification standards.
What it covers
The KYC procedure implements the risk-based classification required by UIF Resolution 49/2024, identification of politically exposed persons, beneficial-ownership identification, and ongoing monitoring. For institutional clients, the KYB component extends to cross-border ownership-tree review and source-of-funds verification. Reviewers pay particular attention to the firm’s handling of jurisdictions with limited corporate transparency or FATF high-risk status.[2]
- Travel Rule Implementation: Procedures for obtaining, retaining, and transmitting originator and beneficiary information for cross-border virtual-asset transfers per FATF Recommendation 16.
What it covers
UIF Resolution 49/2024 requires PSAVs to determine the cases in which they may decline to complete, or must suspend, a virtual-asset transfer that lacks the required originator or beneficiary information.[2] The procedures set out how the firm obtains, retains, and transmits that information, the data fields covered, the counterparty due-diligence applied to receiving VASPs, and the protocol for transfers to or from unhosted wallets. Firms should align with the FATF standard reference threshold of USD/EUR 1,000.
- Transaction Monitoring Framework: Rules-based and behavioural monitoring scenarios, alert thresholds, false-positive management, escalation paths to suspicious-transaction reporting.
What it covers
The Transaction Monitoring Framework documents scenario design (typology-based rules: structuring, rapid movement, sanctions-adjacent activity), threshold-setting logic, alert triage, and the escalation path to reporting to the UIF. The UIF receives suspicious-transaction reports through a defined electronic channel. The framework should evidence at least annual scenario review and the firm’s documented response to UIF feedback.
- Restricted Countries and Jurisdictions Matrix: Internal list of jurisdictions where the firm declines or restricts service, with rationale tied to FATF, OFAC, and EU lists.
What it covers
The restricted-jurisdictions matrix identifies FATF black-listed and grey-listed countries (as of June 2026, Argentina is on neither), OFAC comprehensively sanctioned jurisdictions, EU high-risk third countries, and any firm-specific restrictions. CNV RG 1058/2025 separately bars legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list from registering, so this matrix also informs the corporate-eligibility screen. Review at least at every FATF plenary cycle (February, June, October) and after material sanctions updates.[4]
- STR/SAR Procedures: Internal procedure for suspicious-transaction reporting to the UIF, including the trigger criteria, internal escalation, and tipping-off prohibition.
What it covers
Suspicious-transaction reporting is governed by Law 25.246 and UIF Resolution 49/2024, requiring reports to the UIF where the firm identifies operations that lack apparent economic or lawful justification. Procedures cover the internal escalation chain, the compliance-officer review, the documentation standard, the prohibition on tipping off the client, and record-retention requirements.[2]
- Compliance Monitoring Programme: Annual compliance-officer report, periodic testing schedule, breach-handling procedures.
What it covers
The Compliance Monitoring Programme defines the compliance officer’s annual report, which under CNV RG 1058/2025 is due within 70 calendar days of the end of the calendar year, the periodic testing schedule (typically risk-based, quarterly for high-risk areas), and the breach-handling procedures including remediation timelines and escalation to the board. The CNV reviews the annual report and the prior year’s testing logs at inspection.[4]
- Cybersecurity and Business-Continuity Policy: Required. Governance, identification, protection, detection, and response-and-recovery protocols under Article 13 of CNV RG 1058/2025.
What it covers
CNV RG 1058/2025 Article 13 requires a risk-based cybersecurity programme covering governance, identification, protection, detection, and response-and-recovery, with periodic evaluation of the integrity of stored information by qualified IT professionals.[4] The policy ties into the client-asset segregation controls and the annual external system audit required under Article 20, and should articulate incident-response timelines and the third-party-risk register.
- Data Protection Policies: Compliance with Personal Data Protection Law 25.326 and the supervision of the Agencia de Acceso a la Información Pública.
What it covers
Data protection in Argentina is governed by Personal Data Protection Law 25.326, supervised by the Agencia de Acceso a la Información Pública. The policy addresses consent, purpose limitation, data-subject rights, breach-notification practice, cross-border transfer mechanics (relevant for cloud-based custody and KYC providers), and integration with the AML record-retention obligation.
Business Plan and Financial Projections
Revenue, customer-acquisition, and cost projections; product roadmap mapped to the registered PSAV categories; counterparty list (categories, not names); banking strategy; technology stack and custody architecture. The net-worth evidence has to tie to audited or auditable financial statements, since CNV RG 1058/2025 requires audited statements to be filed within five days of public filing and excludes client assets from the net-worth calculation.[4]
Technology and Operational Documentation
Custody architecture (hot/cold segregation, key-management procedures), cybersecurity policy, business-continuity plan, incident-response procedures, and third-party-risk register. Unlike the EU’s DORA, Argentina has no standalone financial-sector ICT-risk regulation, but CNV RG 1058/2025 Article 13 imposes a cybersecurity governance requirement and Article 20 requires an annual external system audit by certified IT professionals.[4]
Costs and Pricing
Argentina is a mid-cost crypto operating jurisdiction once the substantive net-worth and compliance demands are counted. The statutory part of Year 1, the CNV supervision tasa plus the incorporation or Article 118 registration charges, is USD 9,270 to 10,900, falling to about USD 8,700 a year thereafter. The build around it is estimated at USD 17,000 to 45,000 in Year 1 and USD 15,000 to 34,000 a year after that, quoted per case. Both figures exclude the regulatory minimum net worth itself (USD 35,000 to 150,000 by category), which is locked capital rather than a spend. Government filing fees are modest, but the CNV supervision fee recurs at about USD 8,700 for a legal person; advisory, compliance documentation, the compliance-officer function, and the annual audit account for the rest.[18]
Government / Regulatory Fees
| Fee | Amount (USD equivalent, August 2026) | Source |
|---|---|---|
| Incorporation (S.A. or S.R.L.) or Article 118 branch registration: IGJ tasa and trámite charge, Boletín Oficial notice, and the apostille and sworn-translation chain for documents executed abroad | ~570–2,200 | IGJ and Boletín Oficial tariffs; IGJ Normas art. 34.6[12] |
| Notary (public deed or signature certification) | Quoted per case | Professional fee, not a state charge; outside the statutory total |
| CNV annual supervision fee (tasa de fiscalización y control) | ARS 13,360,000 (legal persons) / ARS 5,344,000 (individuals) for 2026, about USD 8,700 and USD 3,500 at ARS 1,530 to USD 1 on 25 August 2026; payable 3–9 February 2026, or within five business days of registration for a PSAV registered later; amounts re-set annually[23] | CNV RG 1058/2025[4]; CNV tasas schedule[18] |
| Minimum net worth (locked capital, not a fee) | 35,000–150,000 by category; Cat. 1–4 halved below USD 2.5m volume | CNV RG 1058/2025 Art. 9[4] |
| Provincial Ingresos Brutos turnover tax | Varies by province; CABA taxes the dealing margin since 2026 | CABA: Fiscal Code art. 231 as amended by Law 6.926, and AGIP Resolution 93/AGIP/26[19]; other provinces: their own fiscal codes |
The headline is that Argentina’s one-off regulator filing fees are modest, but the regime ties up real capital through the minimum net worth and adds recurring supervisory cost. The expensive parts are the locked net worth, the compliance documentation, and the ongoing officer and audit functions.
Total Cost Summary
Two figures sit inside a single “cost of a PSAV registration” number and they behave differently, so this page publishes them apart. The state and CNV charges are fixed, set by tariff and by RG 1058/2025, and checkable line by line. The work around them is quoted per case.
| Statutory charge (Argentine state and CNV) | Amount (USD) |
|---|---|
| Incorporation (S.A. or S.R.L.) or Article 118 branch registration: IGJ charges, Boletín Oficial notice, and the apostille chain for documents executed abroad (one-off) | 570–2,200 |
| CNV supervision fee (tasa de fiscalización y control), legal person (annual) | 8,700 |
| Statutory cost, Year 1 | 9,270–10,900 |
| Statutory cost, annual (Year 2 onwards) | 8,700 |
The CNV tasa is payable in the first year as well as every year after it, which is why it appears in both statutory totals. It is set in pesos (ARS 13,360,000 for a legal person in 2026) and re-set annually, so the dollar figure moves with the exchange rate. The IGJ annual tasa of a share company, capped at ARS 2,500 (about USD 1.7), is left out of the annual total, and the notary is a professional fee quoted per case.
| Build item (quoted per case) | Amount (USD) |
|---|---|
| Company formation advisory (S.A. or S.R.L., or branch) | 3,000–8,000 |
| CNV PSAV inscription advisory | 5,000–15,000 |
| Compliance documentation (AML/CFT manual, risk assessment, sanctions framework, Travel Rule, transaction monitoring, KYC/KYB, cybersecurity) | 6,000–15,000 |
| Accounting, tax filings and monthly CNV reporting | 3,000–7,000 |
| Typical build, Year 1 (quoted per case) | 17,000–45,000 |
| Compliance documentation refresh (annual) | 2,000–5,000 |
| Accounting, tax filings and monthly CNV reporting (annual) | 4,000–9,000 |
| Compliance officer and public-relations officer, fully loaded (annual) | 6,000–14,000 |
| External system audit (annual) | 3,000–6,000 |
| Typical build, annual (Year 2 onwards) | 15,000–34,000 |
Neither figure includes the minimum net worth (USD 35,000 to 150,000 by category), because that is locked capital held in the entity rather than a spend. Banking application costs are also excluded and are highly variable. The dominant cost driver is the ongoing officer, reporting, and audit load that the supervised regime imposes.
Timeline
| Stage | Duration | Cumulative |
|---|---|---|
| Pre-incorporation (UBO collection, structuring, category selection) | 1–3 weeks | 1–3 weeks |
| IGJ incorporation of S.A. or S.R.L. (or branch under Art. 118) | 4–10 weeks | 5–13 weeks |
| Tax (CUIT, ARCA) and provincial Ingresos Brutos registration | 2–4 weeks | 7–17 weeks |
| Compliance documentation and net-worth evidence | 6–10 weeks | 13–27 weeks |
| CNV PSAV inscription review (TAD filing) | variable | plus CNV review |
| Banking and settlement onboarding | variable, runs in parallel | parallel |
| Total realistic end-to-end | 3–6 months plus CNV review |
The two slow stages are the compliance documentation (a UIF-calibrated AML programme, cybersecurity policy, segregation procedures, and net-worth evidence) and the CNV review of the TAD filing. Incorporation with the IGJ is predictable but not fast. Operators frequently underestimate how much of the schedule is consumed by assembling a documentation set that the CNV will treat as substantive rather than formal. Banking and settlement-account access should run in parallel from the start, not after inscription.
Taxation
Argentina taxes crypto under its general tax code rather than a bespoke crypto regime. Individuals and undivided estates outside a business or sole proprietorship pay the schedular income tax (Impuesto a las Ganancias) on crypto gains at 5% on Argentine-source sales in pesos without an adjustment clause and 15% on sales in foreign currency or foreign-source gains, crypto holdings fall within the personal-assets tax (Impuesto sobre los Bienes Personales), and PSAV company profits are subject to corporate income tax at the standard rate. Most provinces levy a turnover tax (Ingresos Brutos) on crypto trading.[7][8]
The tax position is shaped by Argentina’s wider fiscal context, not by an offshore-style exemption. There is no territorial 0% structure here: a PSAV is a domestic operating company taxed on its profits, and individual users are taxed on gains. Provincial turnover tax is a recurring operating cost that varies by province.
Crypto Tax Treatment
| Tax | Rate | Crypto application |
|---|---|---|
| Corporate Income Tax | Standard company rate (progressive scale) | PSAV company profits taxed as ordinary business income[7] |
| Income Tax on gains (non-business individuals) | 5% or 15% | Crypto gains of individuals and undivided estates outside a business or sole proprietorship, under Impuesto a las Ganancias: 5% on peso sales without an adjustment clause, 15% on foreign-currency sales and foreign-source gains[8] |
| Personal-Assets Tax | Progressive (wealth tax) | Crypto holdings at 31 December under Bienes Personales[7] |
| Turnover Tax (Ingresos Brutos) | Varies by province | On crypto trading; CABA taxes the dealing margin since 2026, not gross turnover[19][9] |
| VAT (IVA) | 21% standard | The purchase and sale of virtual assets is generally outside VAT; the 21% rate can reach fee-based digital or technical services, so treatment is fact-specific[7] |
| Asset-regularisation (blanqueo) 2024 | 5% / 10% / 15% by stage | Closed in 2025; staged rates applied to declared crypto[10] |
Provincial Turnover Tax and the 2026 CABA Change
The Ingresos Brutos turnover tax is levied at the provincial level and is the most operationally significant tax for a trading PSAV. Historically it applied to gross transaction value, which was punitive for high-volume, low-margin exchange activity. The City of Buenos Aires (CABA) now taxes crypto buying and selling on the dealing margin, the difference between purchase and sale price, rather than the full transaction amount: Law 6.926 amended article 231 of the CABA Fiscal Code, and AGIP Resolution 93/AGIP/26 of 6 March 2026 sets the valuation rules, including that swap prices must come from exchanges or dealers registered in the CNV PSAV registry.[19][9] Treatment still varies by province, so the operating province materially affects the tax footprint.
The practical point for operators is that the 5% or 15% rate on non-business individuals understates the total tax footprint of a trading business. Corporate income tax, provincial turnover tax, and the personal-assets tax on holders all interact, and provincial variation means structuring the operating presence is a real decision, not a formality.
The 2024 Asset-Regularisation Programme (Blanqueo)
Argentina ran a temporary asset-regularisation programme in 2024 that allowed taxpayers to declare previously undeclared assets, including crypto, at staged rates: 5% until 31 October 2024, 10% to 31 January 2025, and 15% to 30 April 2025.[10] The programme has closed and is not available in 2026. It is relevant context because it accelerated the formalisation of crypto holdings and dovetailed with the PSAV registry: regularised assets held through registered providers are easier to evidence. Operators should treat the blanqueo as historical, not as a live planning tool.
CRS/CARF Reporting
Argentina participates in the OECD Common Reporting Standard (CRS) and reports through the AEOI framework. The Crypto-Asset Reporting Framework (CARF) is the next phase of automatic exchange for crypto; on the OECD Global Forum list of 14 September 2026 Argentina is among the four jurisdictions committed to first CARF exchanges by 2029.[17][22] The PSAV registry already gives the authorities visibility over registered providers’ activity, which positions Argentina to implement CARF reporting through those providers.
Ongoing Compliance & Post-Registration
A registered Argentine PSAV carries a continuous, supervised compliance load. The recurring obligations are corporate (corporate income tax, audited financial statements), AML (the UIF Resolution 49/2024 programme and reporting), and CNV-specific (monthly transaction reporting, the annual compliance-officer report, and the annual external system audit). Annual statutory cost is about USD 8,700, the CNV supervision fee, and the work around it is estimated at a further USD 15,000 to 34,000 a year depending on scope and volume.[4]
Periodic Reporting Obligations
- AIF AML information filings. RG 1139/2026 brought PSAVs into this CNV reporting regime from 1 July 2026, with the initial complete submission due by 31 July 2026. Beneficial-ownership changes must be reported within 30 calendar days; client-risk segmentation, monitoring and PEP information are updated every six months. AML manuals, officers, risk assessments and internal-control reports have their own update deadlines.[27]
- Monthly transaction report to the CNV: transaction volume and client count, due within 10 days of month-end, from October 2025.[4]
- Annual external system audit, by certified IT professionals, due within 70 calendar days of the end of the calendar year (Article 20).[4]
- Annual compliance-officer report, due within 70 calendar days of the end of the calendar year (Article 21).[4]
- Audited financial statements, filed with the CNV within 5 days of public filing.
- AML reporting to the UIF: suspicious-transaction reports and any periodic reporting required under UIF Resolution 49/2024.[2]
- Corporate income-tax and personal-assets-tax filings with ARCA, plus provincial Ingresos Brutos returns.
- AML training records for staff with customer-contact roles.
Supervision Fees
CNV RG 1058/2025 establishes a registration, supervision, and oversight regime funded by an annual oversight charge (tasa de fiscalización y control): ARS 13,360,000 for legal persons and ARS 5,344,000 for individuals for 2026, payable 3 to 9 February 2026.[18] RG 1103/2026 added PSAVs to the annual fee schedule, so for 2026 they paid in the same window as the other listed obliged subjects, after collection had been suspended until 2 February 2026 under RG 1098/2025. A PSAV registered after the annual window pays the full fee within five business days of registration.[23]
At ARS 1,530 to USD 1 on that is about USD 8,700 for a company, the figure carried in the statutory total above. The larger recurring cost, however, is not the regulator fee but the cost of staffing the compliance officer and public-relations officer functions, commissioning the annual external system audit, and producing the monthly reporting.
Recurring costs beyond any regulator fee: the compliance officer and public-relations officer, the annual external system audit (USD 3,000 to 6,000), accounting and tax filings, the monthly reporting, and the annual compliance-documentation refresh. The locked minimum net worth is a standing obligation as well, re-tested against transaction volume.
Regulatory Inspections
The CNV supervises PSAVs as registered participants. Reviews focus on the AML programme’s design and operation, the cybersecurity controls under Article 13, the integrity of client-asset segregation under Article 16, and the accuracy of the monthly reporting and audited statements.[4] The annual external system audit is itself a recurring examination point. The UIF can act in parallel on the AML side under Resolution 49/2024.
Enforcement
The headline enforcement tool is exclusion from the market: a PSAV that operates without registration, or that loses its registration, can be blocked in Argentina by court order, and registered providers are prohibited from dealing with unregistered counterparties.[3] Non-compliance with the RG 1058/2025 documentation and reporting obligations can result in cancellation of the registration. AML breaches are enforced separately by the UIF under Law 25.246 and Resolution 49/2024, with administrative penalties and referral for criminal money-laundering offences.[2]
The practical reality is that the PSAV registry has teeth precisely because access to the Argentine market depends on it. For an operator whose value is its Argentine user base, deregistration is existential, which is why the regime functions more like a supervised licence than a light register.
Banking
Banking access for Argentine PSAV-registered entities typically rests on PSAV inscription evidence (or a credible application in progress), institutional-grade AML documentation, and director KYC. Argentina’s strict foreign-exchange controls and the peso’s volatility make the banking and settlement layer the hardest part of operating, harder in practice than the registration itself.
The foreign-exchange regime is the defining constraint. Capital controls, the parallel-exchange-rate dynamics, and reporting on cross-border flows mean a PSAV cannot treat banking as an afterthought. Local banks handle peso on-ramp and off-ramp for Argentine users; dollar and multi-currency treasury is generally held externally. Client-asset segregation under Article 16 of CNV RG 1058/2025 must be reflected in the account architecture, not just in the books.[4]
External multi-currency platforms and payment institutions are commonly used alongside local accounts for treasury and cross-border settlement. The typical pattern places domestic peso flows with Argentine banks and holds operating treasury in external multi-currency accounts, while keeping client virtual assets segregated per the regulatory requirement.
The common mistake is sequencing banking after PSAV inscription rather than in parallel. Banking onboarding starts with KYC documentation that overlaps materially with the inscription pack; running them concurrently shortens the critical path. A registration without working banking and settlement is a certificate on the wall: learn about banking for crypto businesses →
Pre-qualified introductions carry more weight in Argentina than in most markets: the account architecture spans local peso banks and external multi-currency platforms, and each layer runs its own diligence under the foreign-exchange regime. Jagelski & Partners scopes banking options in writing and introduces an independent specialist before a registration application is filed. You contract directly with the specialist; account approval remains the financial institution's decision.
Local Argentine banks for peso on-ramp and off-ramp, external multi-currency platforms for USD treasury, and payment institutions for cross-border settlement, structured so client-asset segregation under CNV RG 1058/2025 is reflected in the account architecture from day one.
Explore Banking SolutionsFATF Status & International Standing
Argentina is not on the FATF grey or black list as of .[6] Argentina is a member of both FATF and GAFILAT (Grupo de Acción Financiera de Latinoamérica). The joint FATF/GAFILAT fourth-round mutual evaluation, with an on-site visit in March 2024, was adopted at the October 2024 plenary; FATF concluded that Argentina had strengthened its AML laws and inter-agency coordination since the 2010 evaluation and placed it in enhanced follow-up, which is distinct from grey-list increased monitoring.[6] The report flagged effectiveness shortcomings and made recommendations for improvement.
EU Market Access
An Argentine PSAV does not have EU passporting rights, and MiCA contains no third-country equivalence regime under which the European Commission could recognise an Argentine registration as equivalent to a CASP authorisation.
MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative, for the specific crypto-asset or service requested. ESMA’s guidelines (published , applicable from ) list signs that a firm is likely to be regarded as soliciting, such as EU-targeted marketing, geo-targeted advertising, or EU-based influencers, and judge each case on all the facts; a firm that solicits EU clients cannot rely on the exemption.[11] The exemption does not support systematic EU market access.
For a detailed analysis of what constitutes solicitation and the documentation requirements, see Reverse Solicitation Under MiCA →.
Advantages and Limitations
Argentina offers Latin America’s second-largest crypto market by value received,[21] a now-formalised and FATF-aligned regime, and a clear domestic-market footprint, against a demanding net-worth and supervisory load, hard banking and foreign-exchange conditions, and no EU passporting. The trade-off is strong for operators committed to the Argentine market; poor for operators looking for a cheap offshore wrapper.
- Latin America’s second-largest crypto market.[21] Structural stablecoin demand from inflation and capital-control pressures makes a real Argentine user base a commercial asset.
- Formalised, FATF-aligned regime. A registered PSAV in a jurisdiction off the FATF grey list reads well in correspondent-banking and counterparty diligence.[6]
- Clear category structure and net-worth scaling. Five defined categories, with the minimum net worth for Categories 1 to 4 halved below USD 2,500,000 in 12-month volume, give smaller operators a proportionate entry point.[4]
- Supervised credibility. CNV registration, segregation of client assets, and an annual external audit signal a regulated operator to institutional partners.
- US time-zone alignment. Argentine business hours overlap with US markets, useful for operators serving the wider Americas.
- No EU passporting and no third-country equivalence under MiCA. Mitigation: operators targeting EU clients can obtain a separate CASP authorisation in an EU member state (full market access via passporting) or, where the client acts on its own exclusive initiative, may fall within the narrow reverse-solicitation exemption under MiCA Article 61.
- Banking and foreign-exchange controls are the practical bottleneck. Mitigation: split domestic peso flows from external multi-currency treasury, run banking onboarding in parallel with registration, and reflect client-asset segregation in the account architecture.
- Demanding net-worth and supervisory load. Mitigation: select the lowest-applicable categories, use the sub-USD-2.5m reduced net worth where eligible, and budget the compliance officer and annual audit from the outset.
- No offshore or cheap-wrapper path; local entity unavoidable. Mitigation: where the Argentine market is genuinely yours, Jagelski & Partners scopes the local S.A. or S.R.L. and the registration as one project; where it is not, the lighter Latin American peers (Panama, El Salvador, Costa Rica) are worth comparing, where we can also introduce independent specialists.
- Macro and currency instability. Mitigation: hold treasury in external multi-currency or dollar accounts, and price the provincial turnover tax exposure into the operating-province decision.
How Argentina Compares
Argentina sits in the Latin American peer group alongside Panama (no operative licence; bills pending), El Salvador (DASP registration with the CNAD under the Digital Assets Issuance Law, 0% tax on qualifying digital-asset revenue for registered DASPs), and Costa Rica (no licence; mandatory SUGEF AML/CFT registration under Ley 10961 since 19 September 2026, which is not an authorisation to operate).[24]
Cyprus provides the EU cross-tier reference: MiCA CASP authorisation with full passporting. Each plays a different role in the buyer’s decision, and an independent specialist introduced by Jagelski & Partners covers end-to-end set-up in every one of them.
| Factor | Argentina | Panama | El Salvador | Costa Rica | Cyprus (EU ref.) |
|---|---|---|---|---|---|
| Licence Type | PSAV (VASP) registration with the CNV; mandatory | No licence; bills pending | DASP registration (CNAD); BSP for Bitcoin-only services | No licence; mandatory SUGEF AML/CFT registration under Ley 10961 since 19 September 2026[24] | MiCA CASP authorisation |
| Regulator | CNV (PSAV) / UIF (AML) | None designated for VASPs | CNAD | SUGEF (AML) | CySEC |
| Timeline | 3–6 months to filing + CNV review | 2–4 weeks (corp); banking 1–3 months | 3–6 months | About 3–7 months (excl. SUGEF VASP registration) | 8–14 months |
| Min. Capital | USD 35,000–150,000 net worth by category | Nominal | USD 2,000 | No fixed minimum | Article 67 safeguards: max(EUR 50,000/125,000/150,000 class floor, 25% of previous-year fixed overheads; projected first-12-month overheads for a new firm). Qualifying own funds, insurance/comparable guarantee, or a combination. |
| Year 1 all-in (statutory charges + typical build) | USD 26,270–55,900 | USD 10,560–39,110 | USD 53,800–150,600 | USD 5,700–21,000 | EUR 217,000–462,000 + pro-rata annual fees |
| Corporate Tax | Standard CIT; 5% or 15% on non-business individuals’ gains; provincial turnover tax | 25% local; territorial | 0% on qualifying digital-asset revenue for registered DASPs; 30% otherwise | 30% local; 0% effective foreign-source (territorial) | 15% standard CIT (from 1 January 2026) |
| Local Presence | Argentine S.A./S.R.L. or Art. 118 branch; no offshore-only registration | Resident agent | Legal representative + compliance officer and alternate | Registered office; corporate email for notices | Substantive local presence |
| EU Passporting | No | No | No | No | Yes (30 EEA states) |
| FATF Status | Not grey-listed or black-listed (as of 19 June 2026); see the separate 2024 evaluation and enhanced follow-up. | Not listed | Not listed | Not listed | Not listed |
| Best For | Operators with a genuine Argentine user base | LatAm operators, USD environment, larger banking | Bitcoin-positioned brand, 0% on qualifying DASP revenue | Non-EU operators, territorial tax, low friction | Operators needing full EU market access |
Compare every crypto jurisdiction side by side →
Argentina is the only one of the Latin American group with a fully in-force, supervised PSAV regime that requires real net worth and a local entity. That seriousness is a strength for operators serving the Argentine market and a cost for everyone else. Panama and Costa Rica are lighter and cheaper; El Salvador offers a Bitcoin-native brand and a 0% rate on qualifying revenue of registered DASPs. The decisive question is whether the operator’s users are actually in Argentina.
An independent specialist introduced by Jagelski & Partners delivers PSAV registration in Argentina end-to-end: the local S.A. or S.R.L., the CNV registration filing, banking, and ongoing compliance. The same end-to-end service is available across the Latin American peer group, so the comparison is a genuine choice rather than a steer.
When Argentina Is the Right Choice
Choose Argentina if:
- Your users are genuinely Argentine residents and the local market is your core market.
- You want a supervised, FATF-aligned registration rather than a light offshore register.
- You can fund the minimum net worth and staff the ongoing compliance, audit, and reporting load.
- You can manage Argentine banking and foreign-exchange controls as a known operating cost.
Consider a jurisdiction instead if:
- You want a lower-cost Latin American footprint with a USD environment and larger banking: Panama, where end-to-end set-up is available.
- You want a Bitcoin-native brand and 0% tax on qualifying digital-asset revenue: El Salvador’s DASP registration.
- You want a low-cost regional base with an AML registration rather than a licence: Costa Rica.
- You need systematic EU market access: Cyprus, Lithuania, or Malta via MiCA CASP authorisation.
Register as a PSAV in Argentina
Jagelski & Partners scopes the Argentina PSAV requirements in writing, then introduces the independent specialist who handles formation of the local S.A. or S.R.L., registration filing, banking, and ongoing compliance. The written scope maps the category, net worth, costs, and timeline.
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in Argentine PSAV Applications
Argentina’s regime looks like a simple register but behaves like a supervised licence, and that gap catches first-time applicants. The CNV treats the documentation as substantive, the net-worth and local-entity rules are hard requirements, and the banking and foreign-exchange layer is harder than the registration itself.
- Assuming an offshore structure can register. CNV RG 1058/2025 requires a legal person to be an Argentine S.A. or S.R.L. (S.A.S. excluded) or an Article 118 branch or other permanent representation of a foreign company, and bars legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list. A pure offshore wrapper cannot register; the local-entity step is unavoidable.[4]
- Picking the wrong category set. Registering for more categories than the business needs inflates the net-worth requirement; under-registering risks operating outside the inscription perimeter. Map the actual activities to Categories 1 to 5 before filing, and use the sub-USD-2.5m reduced net worth where eligible.[4]
- Treating net worth as nominal capital. The minimum is real net worth (USD 35,000 to 150,000 by category), client assets are excluded from it, and it is re-tested against transaction volume. It must be funded and maintained, not declared and ignored.[4]
- Adapting a generic AML manual. The UIF expects procedures calibrated to Resolution 49/2024 and to the firm’s actual model. Templates from other Latin American or offshore jurisdictions trigger rework at CNV review and again at banking onboarding.[2]
- Under-resourcing the ongoing obligations. A compliance officer, a public-relations officer, monthly CNV reporting, and an annual external system audit are continuing requirements, not one-off filings. Budget the recurring load from the outset.[4]
- Sequencing banking after inscription. Argentine banking and foreign-exchange controls are the slowest part of the project. Banking onboarding shares KYC documentation with the inscription pack; run them in parallel and segregate client assets in the account architecture from day one.
Frequently Asked Questions
Yes. Crypto is legal in Argentina but is not legal tender; only the Argentine peso has legal-tender status. Virtual assets and their service providers are now formally regulated: Law 27.739, published on , amended anti-money-laundering Law 25.246 to make Virtual Asset Service Providers (Proveedores de Servicios de Activos Virtuales, or PSAV) obligated subjects and ordered the Comisión Nacional de Valores to create a PSAV registry.[1]
CNV General Resolution 994/2024 created the registry on and General Resolution 1058/2025 set the full registration and supervision regime.[4]
Argentina operates a mandatory PSAV registration regime rather than a discretionary licence. Any natural or legal person that, as a business, exchanges, transfers, custodies, administers, or offers financial services around virtual assets to Argentine residents must register with the CNV in the PSAV registry.[5] CNV General Resolution 1058/2025 defines five PSAV categories, minimum net worth of USD 35,000 to 150,000 by category, and a requirement that corporate applicants operate through an Argentine Sociedad Anónima or Sociedad de Responsabilidad Limitada, or through an Article 118 branch or other permanent representation of a foreign company.[4] Operating unregistered can lead to court-ordered blocking of the platform in Argentina.
Plan on three to six months to a complete CNV filing, plus the CNV review, which RG 1058/2025 does not time-limit.[4] Incorporating an Argentine S.A. or S.R.L. with the Inspección General de Justicia runs roughly 4 to 10 weeks. Compiling the AML, cybersecurity, and net-worth documentation runs 6 to 10 weeks of specialist work. The PSAV inscription itself is filed through the Trámites a Distancia (TAD) platform and is reviewed by the CNV.[5] Banking and exchange-account onboarding runs in parallel and is the most variable element.
CNV General Resolution 1058/2025 defines five categories: Category 1, exchange between virtual assets and legal-tender currencies; Category 2, exchange between virtual assets; Category 3, transfer of virtual assets; Category 4, custody or administration of virtual assets or instruments enabling control; and Category 5, participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset.[4] Human persons may only carry out Categories 1 and 2; all other categories require a legal entity.
CNV General Resolution 1058/2025 sets a minimum net worth expressed in US dollars by category: USD 150,000 for Categories 1, 2, and 4; USD 75,000 for Category 3; and USD 35,000 for Category 5. Categories 1 to 4 halve (to USD 75,000, 75,000, 37,500 and 75,000) where the provider is under USD 2,500,000 over the prior 12 months, measured on TRANSACTED volume for Categories 1 to 3 and on CUSTODIED volume for Category 4.
Article 9 excludes Category 5 from the reduction, so USD 35,000 applies at any volume.[4] Client virtual assets must be segregated from the provider’s own assets and cannot count toward the net-worth requirement.
Not by itself. PSAV registration does not authorise the tokenisation or public offering of securities (valores negociables). Argentina does have a separate route for that: Title XXII of the CNV Rules (NORMAS) lets eligible securities, such as shares, corporate bonds (obligaciones negociables), CEDEARs, and financial-trust securities or closed-end fund units backed mainly by real-world assets, be represented digitally where the security itself is authorised and issued in its traditional form, either beforehand or at the same time.[26]
Participating PSAVs must be registered with the CNV in every PSAV category, and General Resolution 1150/2026 extended this controlled sandbox to . Eligibility and offering conditions depend on the instrument. Where the asset is a fund, route via fund licensing.
Individuals and undivided estates outside a business or sole proprietorship pay income tax (Impuesto a las Ganancias) on crypto gains at 5% on Argentine-source sales in pesos without an adjustment clause and 15% on sales in foreign currency or foreign-source gains, and crypto holdings fall within the personal-assets tax (Impuesto sobre los Bienes Personales).[8] Corporate income tax applies to PSAV profits at the standard company rate. Most provinces levy turnover tax (Ingresos Brutos) on crypto trading; the City of Buenos Aires moved in 2026 to tax the dealing margin rather than gross turnover.[9] The 2024 asset-regularisation programme (blanqueo) that taxed declared crypto at staged rates of 5%, 10%, and 15% closed in 2025.[10]
Yes, but it must establish a local footprint. A foreign provider directing services to Argentine residents must register a branch, seat or other permanent representation under Article 118 of Company Law 19.550, or establish an Argentine company, with foreign shareholding registered under Article 123.[4]
Pure offshore registration is not available, and legal persons domiciled, incorporated, or resident in a jurisdiction on both Argentina’s tax-transparency non-cooperative list and the FATF call-for-action list cannot register. The original RG 1058/2025 deadline for foreign providers to establish their local footprint was .
Two figures, not one. The statutory part is USD 9,270 to 10,900 in Year 1 and about USD 8,700 a year thereafter: the CNV supervision fee from its published tariff plus, in Year 1, the incorporation or Article 118 registration charges. The build around it, the entity, advisory and compliance documentation, is quoted per case and is estimated at USD 17,000 to 45,000 in Year 1 and USD 15,000 to 34,000 a year after that. Both figures exclude the regulatory minimum net worth (USD 35,000 to 150,000 by category), which is locked capital rather than a spend. Government filing fees are modest, but CNV RG 1058/2025 added an annual oversight charge (tasa de fiscalización y control) set for 2026 at ARS 13,360,000 for legal persons and ARS 5,344,000 for individuals, payable 3 to 9 February 2026, or within five business days of registration for a PSAV registered later.[18] The dominant recurring costs are the CNV supervision fee, the compliance officer, the annual external system audit, and monthly CNV reporting.[4]
Not on a systematic basis. An Argentine PSAV registration does not grant EU market access or passporting rights, and MiCA contains no third-country equivalence regime. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative for the specific service requested.
ESMA’s guidelines published and applicable from list signs that a firm is likely to be regarded as soliciting, such as EU-targeted marketing, geo-targeted advertising, or EU-based influencers, and judge each case on all the facts; a firm that solicits EU clients cannot rely on the exemption.[11] Operators seeking systematic EU market access should obtain a separate CASP authorisation in an EU member state. See Reverse Solicitation Under MiCA for detail.
No. Argentina is not on the FATF grey list or black list as of . The joint FATF/GAFILAT fourth-round mutual evaluation, with an on-site visit in March 2024, was adopted at the October 2024 plenary; FATF did not grey-list Argentina, but placed it in enhanced follow-up.[6] The PSAV regime under Law 27.739, UIF Resolution 49/2024, and CNV Resolution 1058/2025 was driven in part by FATF Recommendation 15 on virtual assets, which the evaluation scrutinised.
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References
Show all references
- Boletín Oficial de la República Argentina, Ley 27.739 (modificatoria de la Ley 25.246), , boletinoficial.gob.ar, accessed .
- Boletín Oficial de la República Argentina, UIF Resolución 49/2024 (Proveedores de Servicios de Activos Virtuales), , boletinoficial.gob.ar, accessed .
- Boletín Oficial de la República Argentina, CNV Resolución General 994/2024, , boletinoficial.gob.ar, accessed .
- Boletín Oficial de la República Argentina, CNV Resolución General 1058/2025, , boletinoficial.gob.ar, accessed .
- Comisión Nacional de Valores, Registro de Proveedores de Servicios de Activos Virtuales, argentina.gob.ar/cnv, accessed .
- Financial Action Task Force, Anti-money laundering and counter-terrorist financing measures: Argentina, Mutual Evaluation Report (December 2024), fatf-gafi.org, accessed .
- PwC, Argentina Corporate Tax Summaries, taxsummaries.pwc.com, accessed .
- ARCA (Agencia de Recaudación y Control Aduanero), Impuesto a las Ganancias – Criptoactivos, afip.gob.ar, accessed .
- Infobae, El gobierno porteño redujo el pago de Ingresos Brutos a la compraventa de criptomonedas, , infobae.com, accessed .
- Argentina.gob.ar, Se publicó la reglamentación del Régimen de regularización de activos (blanqueo 2024), argentina.gob.ar, accessed .
- European Securities and Markets Authority, Guidelines on reverse solicitation under MiCA (ESMA35-1872330276-2030), , esma.europa.eu, accessed .
- Inspección General de Justicia, Constituir una Sociedad de Responsabilidad Limitada (SRL) and Constituir una Sociedad por Acciones service guides (trámite 24 to 128 módulos) and Calculador de módulos (ARS 1,500 per módulo from 8 April 2024), argentina.gob.ar; Normas de la Inspección General de Justicia, Anexo A to Resolución General IGJ 15/2024, art. 34 inc. 6 (documents from abroad apostilled or legalised, with a sworn translation), with Ley 19.550 art. 10 and the Boletín Oficial tariff under Resolución SLyT 48/2024, argentina.gob.ar, accessed .
- Beccar Varela, Resolución General CNV N°1058: Regulación de Proveedores de Servicios de Activos Virtuales (PSAV), beccarvarela.com, accessed .
- Tavarone, Rovelli, Salim & Miani, Resolución General CNV 1058/2025: Régimen de proveedores de servicios de activos virtuales, tavarone.com, accessed .
- Estudio O’Farrell, The CNV regulates the activities of virtual asset service providers (VASPs), estudio-ofarrell.com, accessed .
- Allende & Brea, Nueva reglamentación para Proveedores de Servicios de Activos Virtuales (PSAVs), allende.com, accessed .
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