Why Choose El Salvador for Crypto Licensing?
El Salvador combines a dedicated digital-assets law with a registration-based regime, a statutory review of up to 20 business days once the file is complete, and a 0% tax stack on regulated crypto activity.[1][26] The CNAD register lists more than 85 digital-asset service providers registered since 2023,[2] anchored by the global headquarters relocation a major stablecoin issuer announced in .[20]
The credibility case rests on four data points:
- The Digital Assets Issuance Law (LEAD) provides a single framework for exchange, custody, trading-platform operation, issuance, and stablecoin services, eliminating the regulatory ambiguity that constrains crypto businesses in most LatAm jurisdictions.[1]
- CNAD’s public DASP registry lists more than 85 providers, numbered up to PSAD-0097 and most recently registered on , including major stablecoin issuers, global exchanges, derivatives, and securities trading firms, and the first traditional Salvadoran retail bank to register.[2][19]
- Article 36 of LEAD exempts registered Digital Asset Service Providers from income tax, capital-gains tax, value-added tax (IVA), municipal taxes and withholding obligations on revenue from Article 19 activities.[3]
- The CNAD 2023–2024 Annual Report records approximately USD 5 billion in approved digital-asset issuances under LEAD, including the first publicly issued, regulator-registered stablecoin from a major issuer.[4][10]
In practice, El Salvador is not a substitute for an EU MiCA licence; it is a complement, a tax-efficient LatAm base for clients who already hold, or are pursuing, a separate authorisation for European market access. The Coincub Crypto Asset Risk Report ranked El Salvador first globally in for crypto regulation and innovation,[5] but the most consequential signal for operators is the registrant list itself.
Regulatory Framework
The Digital Assets Issuance Law (Decreto Legislativo No. 643), published in Diario Oficial No. 16, Tomo 438 on and effective , establishes CNAD as El Salvador’s specialist digital-assets regulator. A second-order reform passed on consolidated supervision over both Digital Asset Service Providers and Bitcoin Service Providers within CNAD. That reform also expanded the AML and counter-proliferation framework. The stablecoin-issuer category is older: the 2023 law already provides for stablecoin issuers, and the first two were registered on .[1][17][30]
Definition: Digital Asset Service Provider
A Digital Asset Service Provider (DASP, or PSAD in Spanish) is, under the Digital Assets Issuance Law, any entity registered with CNAD to perform one or more Article 19 activities: exchange of digital assets for fiat or other digital assets, operation of a digital-asset or derivative trading platform, risk and price evaluation, underwriting, and placement of issuances, structuring, and management of investment products, and third-party custody, transfer, and order execution.
CNAD’s core powers under LEAD Articles 8–11 cover the licensing and supervision of Digital Asset Service Providers, certifiers, and issuers, together with the power to sanction them; approval of public offerings of digital assets; issuance of secondary regulations; and coordination with the Unidad de Investigación Financiera (UIF) on AML/CFT matters.[1]
President Juan Carlos Reyes leads a 35-person organisation that has signed Memoranda of Understanding with the Astana International Financial Centre alongside Argentina and Paraguay, and held a working meeting with the US SEC Crypto Task Force on to propose a cross-border regulatory sandbox.[6]
The October 2024 reform package brought three structural changes. First, it removed the Banco Central de Reserva (BCR) and the Superintendencia del Sistema Financiero from digital-asset oversight, although, as of September 2026, BCR still operates the Bitcoin Service Provider register, continues to add registrations and states that the authorisation to operate is issued by CNAD; the transfer to CNAD is legislated but incomplete.[18][24] Second, it limited DASP applicants to a sociedad anónima or a foreign branch, usually a Sociedad Anónima de Capital Variable (S.A. de C.V.); the CNAD register nonetheless lists simplified joint-stock companies (SAS) among its registrants, the first on .[2]
Third, it codified a territoriality principle limiting DASP operations to El Salvador’s jurisdiction, with outbound cross-border activity subject to destination-jurisdiction rules.[7]
Bitcoin Law: Acceptance Made Voluntary, DASP Framework Unaffected
Decreto Legislativo No. 199 of (effective approximately ) kept Bitcoin’s statutory legal-tender status (curso legal) but ended compulsory acceptance: acceptance is now voluntary and confined to the private sector, with the public sector prohibited from accepting it. Articles 4, 8 and 9 of the Bitcoin Law (Bitcoin tax payments, State conversion infrastructure) were repealed; Article 5 (the 0% capital-gains exemption on Bitcoin exchanges) was retained.[8] The IMF Country Report 25/58 describes the reform as having eliminated Bitcoin’s characterisation as currency.[9] The IMF approved a 40-month, USD 1.4 billion Extended Fund Facility (EFF) on and listed this reform among the programme’s prior actions.[15] The DASP framework under LEAD is unaffected by these changes.
License Types and Activities Covered
LEAD Article 19 defines the activities requiring a DASP registration: exchange of digital assets for fiat or other digital assets; operation of a digital-asset or derivative trading platform; risk and price evaluation; underwriting and placement of digital-asset issuances; structuring, management or promotion of digital-asset investment products; and third-party operations (custody, transfer, order receipt and transmission, and derivative-order execution).
CNAD organises the public registry into five activity classes: Risk and Price Evaluators, Structurers, Exchange, Asset Storage and Custody, and Issuances Platforms.[2]
Three further authorisations sit on the issuance side. Digital-Asset Issuer covers any entity issuing a digital asset under LEAD; Stablecoin Issuer, provided for since the 2023 law and first registered in June 2024, pays fees scaled to planned 12-month issuance volume;[30] Certifier is an independent attestation function, with Chiltex S.A. de C.V. the first registrant on .
| Category | Scope | Notes |
|---|---|---|
| Digital Asset Service Provider (DASP / PSAD) | Article 19 activities: exchange, custody, trading platform, issuance underwriting, placement, third-party transfer | Article 36 tax exemption applies. Five activity classes in CNAD registry. |
| Digital-Asset Issuer | Public or private offering of any digital asset under LEAD | Issuance authorisation fee 0.01% of offer size; certification USD 50. |
| Stablecoin Issuer (“Emisor de Stablecoin”) | Public offering of stablecoins | Provided for since 2023. Fees scaled to 12-month planned volume. First registrants: Moon Gold El Salvador and Moon Gold NA (EME-0001/0002, 20 June 2024) issuing aUSDT.[30] |
| Certifier | Independent attestation services | Article 36 tax exemption applies. |
| Bitcoin Service Provider (BSP / PSB) | BTC ↔ USD exchange, Bitcoin payment processing, Bitcoin remittance, Bitcoin custody (with or without wallet custody) | Does NOT qualify for Article 36 LEAD tax exemption. Bitcoin-only operations may register only as a BSP; multi-asset operators typically register as both DASP and BSP. BCR still operates the registry (September 2026); CNAD issues the authorisation to operate. |
Tokenised securities and RWA
Tokenised real-world assets can use the CNAD digital-asset offering regime, but this is not an ordinary securities authorisation. Article 3 of the Digital Assets Issuance Law (LEAD) states that digital assets are not títulos valores and excludes the listed securities-law regimes. The token's rights, offering and issuer therefore need to be structured under LEAD; a DASP service registration alone does not approve an issuance.[1]
Classify the proposed asset and vehicle before choosing the route. A tokenised fund structure requires its own analysis; see our fund licensing guidance.
Bitcoin Service Provider (BSP) Pathway
The Bitcoin Service Provider registry is kept by the Banco Central de Reserva under the Bitcoin Law regulations (Executive Decree No. 27 of ), pending operational transfer to CNAD; the BCR’s Norma Técnica NRP-29 restates that registration duty in its article 10 and otherwise governs banks, investment banks, cooperative banks, savings-and-credit societies and e-money providers that offer Bitcoin-based services to their own clients, directly or through a Bitcoin Service Provider, or provide banking services to one.[11] As of the BCR register lists 300 Bitcoin Service Providers, 23 of them suspended.[24] The common mistake is registering as a BSP when the business model is not Bitcoin-only: altcoin and stablecoin services, along with tokenised assets, require a DASP registration, and BSP-only registrants do not qualify for Article 36 tax benefits.
Requirements
CNAD registration requires a Sociedad Anónima de Capital Variable (S.A. de C.V.) or a foreign branch, a minimum of two shareholders (100% foreign ownership permitted, no residency requirement for shareholders or directors), a legal representative whose registered credential or general power goes in the file (the Commercial Code imposes no residency condition on the representative of a Salvadoran S.A., but a foreign branch’s representative must reside permanently in El Salvador),[26][27] a compliance officer and an alternate appointed by the board and notified to the UIF, whose qualifications the UIF instructivo sets,[23] and a designated director responsible for cybersecurity coordination. Even so, S.A.S. de C.V. companies have appeared on the CNAD register since January 2025.[2]
| Requirement | Specification |
|---|---|
| Corporate form | S.A. de C.V. or foreign branch; S.A.S. de C.V. registrants also on the register |
| Minimum capital | USD 2,000 fully subscribed for an S.A.; at least 5% of each cash contribution paid at incorporation (USD 100 on the minimum capital), with the balance due within one year of registration of the incorporation deed. Non-cash contributions must be paid in full at incorporation.[32] LEAD art. 21(h) separately requires adequate financial and non-financial resources as the CNAD sets.[1] |
| Shareholders | Minimum two; 100% foreign ownership permitted |
| Directors | Fit-and-proper review via CNAD KYC/KYB; cybersecurity coordinator designated |
| Legal representative | Required; resident only for a foreign branch (Commercial Code art. 358(c))[27] |
| Compliance officers | Compliance officer and alternate, appointed by the board; qualifications set by the UIF instructivo (Decreto 426 art. 20)[23] |
| Registered office | Required in El Salvador |
| Business plan | Three-year forward plan covering services, target market, financial projections |
| AML/KYC programme | Policies, transaction-monitoring, sanctions-screening procedures aligned with the 2025 Ley Especial (Decreto 426) and the CNAD LDA-FT-ADM Guide |
| Cybersecurity programme | Information-security policies, business-continuity and disaster-recovery procedures proportionate to services |
| Audited opening balance | Certified by a registered Salvadoran CPA |
| Operational rules | Written rules for each crypto service offered |
The CNAD pre-registration document set (RPSAD Articles 7, 17–35) is comprehensive; complete dossier preparation is the dominant time variable. Experienced applicants prepare the AML and cybersecurity documentation, together with business-continuity material, in parallel with entity formation rather than sequentially: sequential preparation can add 6–8 weeks to the project.
Application Process
The CNAD process runs in two formal stages: pre-registration (an “objection / no-objection” filter that establishes territorial and material competence under LEAD Articles 2 and 4) and definitive registration (the substantive review). The CNAD has up to 20 business days to resolve a complete file;[1][26] realistic total time from project kickoff to registration certificate is 3–6 months, with complex business models running 7–9 months.
Entity Formation and Banking Setup
Incorporate the S.A. de C.V. via the Centro Nacional de Registros (CNR); obtain NIT/NRC tax identifiers; appoint the legal representative and the compliance officer and alternate;[26][23] open the local bank account during this stage. Detail in the El Salvador company formation guide. A bank account is not part of the CNAD registration file.[1][26]
Pre-Application Document Preparation
Three-year business plan; AML/KYC and transaction-monitoring policies, with sanctions-screening procedures; cybersecurity procedures covering BCP and DR; operational rules per crypto service; audited opening balance certified by a registered Salvadoran CPA; notarised and apostilled passports and academic credentials for shareholders and directors. In parallel with Stage 1 where possible.
Pre-Registration Submission
Submit the CNAD pre-registration form via the official portal. CNAD performs an initial evaluation and may request additional information. The applicant supplements the file as needed.
“Objection / No-Objection” Decision
CNAD evaluates territorial competence (LEAD Article 2) and material competence (Article 4). A “no objection” outcome permits the applicant to submit the full file for definitive registration.
Definitive Registration Submission
Submit the full documentation set in digital and physical format at CNAD’s offices.
Statutory CNAD Review
If the file is incomplete, the CNAD notifies the applicant, who has 10 business days to complete it under the 2023 Reglamento; the LEAD itself states five.[1][26] The CNAD may request additional information before its deadline and sets the period for the reply; each significant change the applicant notifies before the resolution gives the CNAD 5 further business days.[26]
Favourable Resolution and Fee Payment
Following a favourable resolution, the USD 6,132 initial registration fee is payable within 10 days in USD or BTC.
Registration Certificate
CNAD issues the registration certificate. Article 36 tax benefits apply from the notification date of the definitive registration number. CNAD notifies UIF of the new licensee.
Compliance Documentation Build-Out
The LEAD-aligned AML programme, the cybersecurity and BCP framework, and the operational rules are drafted within the licensing engagement by the independent specialist introduced for the case, in parallel with entity formation, so the documentation arrives at CNAD as a coherent package rather than a stack of independently sourced templates. Governing reference points for the AML build are the January 2024 asset-freezing reform and the 2025 Ley Especial contra el Lavado de Activos (Decreto Legislativo No. 426), read against the CNAD LDA-FT-ADM Guide.
The 20-business-day period applies to a complete file: an incomplete file first goes back to the applicant for completion, and each significant change notified before the resolution adds five business days.[1][26]
Required Documents
The CNAD dossier comprises three layers. Corporate documentation covers the entity together with its shareholders and directors; the substantive business package sets out the plan and financial projections alongside operational rules; the compliance layer covers AML, cybersecurity, BCP and the audited opening balance. Spanish-language certified translation is required for all foreign-source documents; apostille is required on passports and academic credentials, plus shareholder corporate documents.
| Document Category | Specific Documents |
|---|---|
| Corporate | Articles of incorporation; commercial registry certificate; shareholder register; director appointments; legal representative credential or general power[26]; NIT and NRC certificates |
| Identity & background | Notarised, apostilled, and translated passports of shareholders and directors; academic credentials; criminal record certificates; fit-and-proper declarations |
| Business package | Three-year business plan; financial projections; target-market analysis; pricing model; operational rules per crypto service offered |
| Compliance | AML/KYC policy; transaction-monitoring procedures; sanctions-screening procedures; suspicious-activity reporting workflow; cybersecurity policy; business-continuity and disaster-recovery plan; data-protection programme |
| Financial | Audited opening balance certified by a Salvadoran-registered CPA; capital paid-in proof |
Compliance Documentation Drafting
An independent specialist introduced by Jagelski & Partners coordinates the drafting and assembly of the full CNAD documentation pack through specialist Salvadoran counsel and compliance partners, sequencing the AML/KYC policy, cybersecurity and business-continuity procedures, operational rules, and fit-and-proper documentation so the application opens with a complete file. Drafting Salvadoran-specific procedures referencing the 2025 Ley Especial (Decreto 426) and the CNAD LDA-FT-ADM Guide by name, rather than adapting a generic offshore template, is the better preparation for the pre-registration evaluation.
Costs and Pricing
El Salvador publishes its regulator fees in statute, so the statutory cost is exact: USD 6,286 to 6,336 in Year 1 and USD 4,231 a year thereafter. Everything else is the build, quoted per case, and it is estimated at USD 47,500 to 144,300 in Year 1 and USD 39,200 to 116,000 a year from Year 2. CNAD’s USD 6,132 registration fee is small against that; staffing and substance are the dominant cost drivers.
Statutory Cost
| Statutory item | Amount (USD) |
|---|---|
| CNAD initial DASP registration fee: fifteen minimum monthly wages in the commerce and services sector (USD 408.80 since 1 June 2025), payable in USD or BTC within 10 days of a favourable resolution (single payment on registration)[28] | USD 6,132 |
| CNR registry charges on incorporation: deed inscription, matrícula, local registration, and initial balance-sheet filing, for a minimum-capital S.A. de C.V.[29] | 154.26 |
| Issuance certification, per issuance, if the applicant issues tokens | 50 |
| Public-offering authorisation at 0.01% of offer size: issuer-side, and not applicable to pure service providers | Scaled |
| Statutory cost, Year 1 | 6,286–6,336 |
| CNAD renewal: ten minimum wages in the commerce and services sector, payable in the first quarter of each year, and moving if that wage does (annual) | USD 4,088 |
| CNR annual registry charges from Year 2: matrícula renewal, local renewal, and year-end balance-sheet deposit (annual)[29] | 142.86 |
| Statutory cost, annual from Year 2 | USD 4,231 |
From Year 2 the statutory cost is the CNAD renewal of USD 4,088 plus USD 142.86 of annual CNR registry charges (matrícula renewal, local renewal, and year-end balance-sheet deposit), USD 4,231 in all.[29] Both CNAD figures are set in minimum wages by LEAD article 12 and move with the commerce and services minimum wage, which Decreto Ejecutivo No. 11 raised to USD 408.80 a month from 1 June 2025, so they can be checked rather than quoted.[1][28] CNAD’s registration page still shows USD 5,475, the figure at the earlier USD 365 wage.[7] Stablecoin-issuer fees are scaled to planned 12-month issuance volume and sit outside this table.
Typical Build Cost (quoted per case)
| Build item | Amount (USD) |
|---|---|
| Entity formation (S.A. de C.V.): notarial and legal fees on top of the CNR registry charges in the statutory table above | 1,316–3,316 |
| Legal and advisory, first year: scope-dependent, with banking and compliance setup at the upper end | 12,000–35,000 |
| Local director and legal representative, first-year retainer | 6,000–18,000 |
| Compliance officer and alternate[23] for the first year, two posts at local salary rates | 24,000–60,000 |
| Office, first year: coworking at USD 100 a month to physical premises at USD 1,500 a month | 1,200–18,000 |
| External audit by a Salvadoran-registered auditor, first year | 3,000–10,000 |
| Capital lock-up: USD 100 at incorporation, balance within 12 months (held, not spent; outside both totals) | 2,000 |
| Typical build, Year 1 (quoted per case) | 47,500–144,300 |
| Legal and advisory (annual) | 5,000–10,000 |
| Local director and legal representative (annual retainer) | 6,000–18,000 |
| Compliance officer and alternate[23], two posts at local salary rates (annual) | 24,000–60,000 |
| Office (annual) | 1,200–18,000 |
| External audit by a Salvadoran-registered auditor (annual) | 3,000–10,000 |
| Typical build, annual ongoing from Year 2 (quoted per case) | 39,200–116,000 |
The office and staffing ranges in the table are estimates for mid-2026 San Salvador conditions and should be refreshed annually.
Timeline
Total time from kickoff to operational DASP status runs 3–6 months for standard business models, and 7–9 months for complex multi-licence structures or stablecoin issuers requiring scaled fee assessment. Statutory CNAD review takes up to 20 business days once the file is complete;[1][26] the headline number understates total calendar time because banking and document apostille sit outside the statutory clock.
| Phase | Duration | Notes |
|---|---|---|
| Entity formation | 1–2 weeks | CNR registration; NIT/NRC issuance |
| Local banking | 3–8 weeks | The single biggest schedule risk. Not a filing prerequisite; start it in parallel |
| Document apostille (foreign-source) | 2–4 weeks | Run in parallel with entity formation |
| AML and compliance documentation build | 4–6 weeks | Parallel with entity formation where possible |
| Pre-registration: CNAD evaluation | 4–8 weeks | Includes information-request cycle |
| Definitive registration: statutory review | Up to 20 business days for a complete file | Incomplete file: 10 business days to complete under the Reglamento (5 under the LEAD); each notified significant change adds 5 business days[1][26] |
| Certificate issuance and UIF notification | 1 week | After favourable resolution and fee payment |
| Total (standard) | 3–6 months | – |
| Total (complex) | 7–9 months | Stablecoin issuers, multi-entity structures, dual DASP + BSP |
Taxation
LEAD Article 36 exempts registered Digital Asset Service Providers, along with certifiers and issuers, from corporate income tax, capital-gains tax, ordinary income tax, value-added tax (IVA at 13%), municipal taxes and the obligation to withhold those taxes on revenue derived from Article 19 digital-asset activities.
Non-Article-19 income (consulting and advisory work, or fiat-only services) remains subject to corporate income tax at the standard 30% of net taxable income, or 25% for a company whose gross taxable income (rentas gravadas) for the year does not exceed USD 150,000.[21] Bitcoin Service Providers do not qualify for Article 36 exemptions, a structural asymmetry that should drive licence-pathway selection.
| Tax | Standard Salvadoran Rate | Registered DASP / Issuer / Certifier on Article 19 Revenue | BSP-Only Provider |
|---|---|---|---|
| Corporate income tax | 30% (25% if gross taxable income ≤ USD 150,000) | 0% | 30% (25% tier) |
| Capital gains tax | 10% | 0% | 0% on Bitcoin only (Art. 5 Ley Bitcoin retained) |
| Value-added tax (IVA) | 13% | 0% on Article 19 services | 13% |
| Municipal taxes | Variable | 0% | Variable |
| Dividend withholding (shareholder) | 5% | 0% on dividends from Article 19 profits (Art. 36(d)); 5% otherwise | 5% |
| Dividend withholding (tax-haven recipient) | 25% | 0% on dividends from Article 19 profits (Art. 36(d)); 25% otherwise | 25% |
The 5% dividend withholding rate jumps to 25% when the recipient sits in a tax haven or preferential regime, per Salvadoran general tax law.[12] Article 36(d) of the LEAD extends the exemption to shareholders for dividends paid out of the exempt digital-asset activity,[1] so the higher rate bites on dividends from other profits, such as advisory or fiat-only income, and holding-company routing through listed jurisdictions such as Belize or Cayman still matters for mixed revenue.
What the LEAD Tax Exemption Does Not Cover
LEAD Article 36 covers Article 19 activities and direct income derived from them. Bitcoin Service Provider income falls outside it, as do advisory and consulting fees beyond Article 19 scope and operations exchanging digital assets for goods or services not detailed in Article 19. Free-zone benefits (15–20 year income-tax exemptions) sit under separate legislation (Ley de Zonas Francas) and require independent qualification.
Ongoing Compliance & Post-Registration
CNAD-registered DASPs file quarterly financial reports, maintain AML/CFT programmes aligned with the 2025 Ley Especial contra el Lavado de Activos (Decreto Legislativo No. 426), which replaced the 1998 Ley Contra el Lavado de Dinero y de Activos, and with the CNAD LDA-FT-ADM Guide,[23] submit annual audited financial statements, and notify CNAD of any material change in services, ownership or directors. The October 2024 reform added explicit counter-proliferation (CPWMD) obligations.
Core ongoing obligations:
- Quarterly reporting to CNAD. Financial statements and activity reports on a Jan/Apr/Jul/Oct cycle.
- AML/CFT programme. Risk assessment, customer due diligence, transaction monitoring, suspicious-activity reporting to UIF, sanctions screening against the UNSC consolidated list. OFAC screening is de facto required given USD legal-tender status and correspondent-banking exposure.
- Travel Rule. Implementation aligned with FATF Recommendation 16. The statute itself sets no de minimis: article 25 of the 2025 AML law makes cash, wire, and digital-asset transactions reportable to the UIF within five working days and delegates the thresholds to the law’s reglamento. Until both the new reglamento and a new UIF instructivo are issued, article 61 keeps the 2000 reglamento and the UIF’s instructivo of 22 October 2021 (amended in 2023) in force, so the operative figures are still the instructivo’s: single cash transactions above USD 10,000, other means above USD 25,000 and international wires of USD 1,000 or more.[23][31]
- Annual external audit. Auditor registered with the Commercial Registry; Tax Auditor appointment by after fiscal year-end.
- Material change notifications. Service expansion, shareholder changes (≥ 5% threshold), director changes, key personnel changes.
- Cybersecurity programme maintenance. Information-security policies reviewed at least annually, along with BCP and DR procedures. No separate CNAD ICT technical norm exists outside the registration package.
- Sanctions screening. UNSC consolidated list mandatory; OFAC compliance de facto required.
The Ley Especial contra el Lavado de Activos (Decreto Legislativo No. 426 of , Diario Oficial No. 190, Tomo 449, in force eight days after publication) replaced the 1998 Ley Contra el Lavado de Dinero y de Activos and will require programme updates from registered entities through 2026. It brings digital-asset transactions into the reporting regime expressly, and its thresholds arrive with the reglamento rather than with the law.[23][13]
Banking
Local USD banking is a major operational constraint on an El Salvador DASP project, despite USD legal-tender status since 2001. A traditional Salvadoran retail bank became the first to obtain CNAD DASP registration on ,[2] but the broader local-bank appetite for crypto-business accounts remains selective. Neither article 20 of the Ley de Emisión de Activos Digitales nor article 7 of the 2023 Reglamento de Proveedores de Servicios de Activos Digitales puts a bank account or a bank reference in the registration file, so an account is not a filing prerequisite.[1][26]
What is left is a scheduling problem rather than a legal one. Bank onboarding runs 3–8 weeks on its own clock, independent of where the CNAD file has reached, so a project that leaves it until after the registration resolution simply adds that block to the end of the critical path. International crypto-friendly Electronic Money Institutions remain the practical instrument for ongoing payment flows and merchant settlements; local banks serve as the regulatory anchor and operating-currency account.
Jagelski & Partners arranges banking introductions into specialist USD correspondent and EMI relationships set up for CNAD-registered DASPs, calibrated to the entity’s business model and counterparty geography. Three variables determine outcome: substance and ownership transparency, plus the ABC/sanctions footprint of each ultimate beneficial owner; pricing and turnaround are secondary.
Background: BCR raised banks’ required reserves to 12% of deposits at end-January 2025, with further liquidity-requirement increases to 13% at end-June 2025, 14% at end-December 2025 and 15% at end-June 2026, under the IMF EFF programme (IMF Country Report 25/58).[9] This prudential tightening is improving correspondent-banking comfort with Salvadoran-bank exposure, though the effect on day-to-day crypto-business onboarding remains incremental.
Jagelski & Partners’ banking partner network spans the USD correspondent, European, and LatAm corridors, and includes specialist EMIs and traditional banks as well as payment institutions. A licence without banking access is a certificate on the wall: learn about our Banking service →
Jagelski & Partners scopes banking options in writing and introduces an independent specialist before a licence application is filed. You contract directly with the specialist; account approval remains the financial institution's decision.
Local USD operating accounts as the regulatory anchor, specialist USD correspondent relationships, and international EMIs for ongoing payment flows and merchant settlement, matched to each DASP’s flow profile and counterparty geography.
Explore Banking SolutionsFATF Status & International Standing
El Salvador has been a full GAFILAT member since 2022 and was on neither FATF list after the June 2026 plenary.[22] The 4th-round Mutual Evaluation Report by GAFILAT, conducted on-site in and adopted at the GAFILAT XLIX Plenary in , identified deficiencies in the depth of risk understanding for terrorism financing and virtual assets, with legal persons a further gap, plus limited supervision of non-financial sectors and sanctions proportionality.[14] The deficiencies did not trigger grey-listing.
International Standing
CNAD’s international engagement includes MOUs with the Astana International Financial Centre alongside Argentina and Paraguay; the CNAD–US SEC Crypto Task Force meeting of proposing a cross-border regulatory sandbox;[6] Coincub’s Crypto Asset Risk Report ranking El Salvador first globally in ;[5] and the inaugural Digital Assets Symposium (DAS) hosted by CNAD on . The First EFF Review report 25/190 (June 2025) asks for continued efforts to bring the AML/CFT framework into line with FATF standards,[16] and IMF Press Release 25/440 of notes the new AML/CFT law approved in Q4 2025 as a programme milestone.[13]
EU Market Access
A Salvadoran CNAD DASP registration does not confer EU passporting rights; serving EU clients lawfully requires either reverse solicitation under MiCA Article 61, which is narrow in scope and unsuitable as a marketing strategy, or holding a separate CASP authorisation in an EU jurisdiction. See Reverse Solicitation Under MiCA → for the legal framework and operational implications.
US Market Access
The USD legal-tender status creates a shared currency environment but no cross-border arrangement with US authorities. US-customer-facing business still requires FinCEN MSB registration plus the relevant state Money Transmitter Licences. The CNAD–SEC Crypto Task Force meeting of April 2025 proposed a cross-border regulatory sandbox; as of this is not yet operational.
LatAm Regional Standing
El Salvador’s CNAD framework is a dedicated crypto-issuance regime, with MOUs supporting regional licensing strategy and a Spanish-language operating environment that reduces friction for LatAm-targeting businesses.
Advantages and Limitations
El Salvador buys a dedicated digital-assets framework, a 0% tax stack on regulated activity, a fast statutory review and a high-profile registrant cohort, at the cost of no EU passporting and a selective local banking environment, plus a genuine substance requirement.
- Dedicated digital-assets framework with public-offering regime. LEAD provides a single legal basis for exchange, custody, trading, issuance, and stablecoin services, with a dedicated public-offering pathway for tokenisation issuers.
- 0% tax stack on Article 19 activities. LEAD Article 36 exempts registered providers from CIT, CGT, IVA, municipal taxes, and withholding obligations on digital-asset revenue.
- Statutory CNAD review of up to 20 business days. The CNAD must resolve a complete file within that period (LEAD art. 20; Reglamento art. 8).[1][26]
- USD operating currency. Eliminates FX risk for USD-denominated business; reduces friction for US and international clients.
- High-profile registrant cohort. A major stablecoin issuer’s global HQ relocation, a leading exchange group’s spot/derivatives/securities consolidation, further global exchanges, and a local retail bank: credible-name validation for the regime.
- Not FATF grey-listed. GAFILAT MER adopted August 2024 without monitoring designation.
- No EU passporting. A Salvadoran DASP does not grant rights to serve EU clients. Mitigation: pair the CNAD DASP with an EU MiCA CASP in Lithuania, Ireland or France for European market access.
- Local banking is the operational bottleneck. Local-bank appetite is selective, and onboarding runs 3–8 weeks on its own clock independent of where the CNAD file has reached. Mitigation: start the local USD account alongside entity formation rather than after the CNAD resolution; arrange international EMI relationships for ongoing flows.
- 25% dividend WHT on tax-haven recipients outside the exemption. Dividends from non-Article-19 profits routed through listed jurisdictions such as Belize or Cayman trigger the higher rate. Mitigation: structure the holding chain through a non-listed jurisdiction with an appropriate tax-treaty or transparency profile.
- Bitcoin Law future is contingent on IMF programme compliance. Decreto 199 kept Bitcoin’s statutory legal-tender status but made acceptance voluntary; further amendments are possible under the EFF. Mitigation: structure Bitcoin-specific business under the LEAD DASP framework rather than as a BSP-only entity.
- Substance is genuinely required. A compliance officer and alternate, a legal representative[23][26], a registered office and an audited opening balance. Mitigation: budget realistic local salaries and physical-office costs; do not attempt a low-substance shell structure.
- BSP regime is in operational transition. Legal supervision transferred to CNAD in October 2024 but BCR continues to administer the BSP registry. Mitigation: register multi-asset operations as a DASP under CNAD and treat BSP as a complement only where Bitcoin-specific services are core.
How El Salvador Compares
El Salvador occupies a distinct position in the LatAm and offshore crypto-licensing landscape: dedicated digital-assets law, fast statutory review, 0% tax stack on regulated activity, and a high-profile registrant cohort. Against the closest LatAm peers (Panama, Costa Rica) and an established offshore reference (Bermuda), El Salvador wins on regulatory specificity and tax; against EU MiCA jurisdictions (Malta as cross-tier reference) it loses on passporting and institutional banking depth.
| Factor | El Salvador | Panama | Costa Rica | Bermuda | Malta (EU ref.) |
|---|---|---|---|---|---|
| Licence Type | DASP (CNAD) under LEAD | No dedicated crypto licence or registration | No licence; mandatory SUGEF AML/CFT registration under Ley 10961 since 19 September 2026[25] | Class F or M digital-asset business under DABA | MiCA CASP |
| Regulator | CNAD | None designated for VASPs | SUGEF / BCCR | Bermuda Monetary Authority (BMA) | Malta Financial Services Authority (MFSA) |
| Timeline | 3–6 months | 6–16 weeks (no licence) | About 3–7 months (excl. SUGEF VASP registration) | 6–12 months | 9–18 months |
| Capital / prudential safeguards | USD 2,000 subscribed for an S.A.; if cash-funded, at least USD 100 initially paid; CNAD resource requirements are separate | None statutory | None statutory | USD 100,000 baseline net assets (Class M and Class F; BMA may direct higher) | Annex IV class floors: EUR 50,000–150,000 (category-dependent) |
| Year 1 all-in | USD 53,800–150,600 | USD 10,560–39,110 | USD 5,700–21,000 | USD 377,000–1,610,000 (Class F; statutory fees + typical build) | EUR 490,000–1,075,000 build + statutory fees |
| Corporate Tax | 0% on Art. 19 activity; 30% otherwise | 25% territorial | 30% on local-source income | 0% standalone; 15% CIT from for in-scope MNEs | 35% headline; effective ~5% with refund |
| Local Presence | Legal representative + compliance officer and alternate[26][23] | Local agent only | Registered office; corporate email for notices | Substantial operational presence required | Local directors and qualifying employees |
| EU Passporting | No | No | No | No | Yes – full EEA passporting |
| FATF Status | Not grey-listed; GAFILAT member | Not grey-listed | Not grey-listed | Not grey-listed | Not grey-listed; EU member |
| Best For | Tokenisation issuers; LatAm exchanges; stablecoin issuers; Bitcoin-native businesses | LatAm-focused service providers seeking speed | Lean LatAm operations | Institutional digital-asset funds and brokers | EU/EEA-targeting CASPs |
For MiCA CASPs, the amounts shown are Annex IV class floors. Prudential safeguards must equal at least the higher of the applicable Annex IV class floor and 25% of the previous year’s fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply. Qualifying own funds, an insurance policy or comparable guarantee, or a combination may meet the requirement. MiCA Article 67(1)–(4).
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El Salvador’s structural advantage over Panama and Costa Rica is the existence of a dedicated digital-assets law and an Article 36 tax exemption with measurable take-up. Panama and Costa Rica operate without a dedicated crypto framework, which keeps cost and timeline lower but leaves clients in a legal grey zone for issuance and stablecoin work.
Bermuda’s Class F / Class M regime under the Digital Asset Business Act offers higher prestige and an established institutional-banking footprint, but with a USD 100,000 baseline net-asset floor (which the BMA may direct materially higher) and Class F Year 1 costs roughly 7–11× El Salvador’s. The right read is jurisdictional fit by use case: institutional fund structures and high-net-worth-facing brokers favour Bermuda; tokenisation and stablecoin issuers favour El Salvador, as do LatAm-facing exchanges.
Against Malta as the cross-tier EU reference, El Salvador trades MiCA passporting for tax efficiency and regulatory specificity; operators with material EU revenue should pair the two.
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in El Salvador Applications
Six errors worth avoiding in an El Salvador DASP application concern banking sequencing, scope-of-licence misunderstanding, the BSP-vs-DASP tax asymmetry, dividend-WHT structuring, substance underestimation, and foreign-document translation and apostille.
- Leaving the local bank account until after the CNAD resolution. See Banking above: the CNAD file does not require an account,[1][26] but onboarding runs 3–8 weeks on its own clock, so deferring it adds that block to the end of the critical path.
- Registering only as a Bitcoin Service Provider for a multi-asset business model. Any altcoin, stablecoin, NFT or tokenised-asset activity requires a DASP registration, and BSP-only registrants forfeit the Article 36 tax exemption (see License Types).
- Routing dividends through a listed tax-haven holding company. Outside the Article 36(d) exemption, dividend withholding rises from 5% to 25% on tax-haven recipients (see Taxation).
- Treating Article 36 as a blanket exemption. It covers Article 19 activities only; business plans mixing licensed services with substantial non-LEAD revenue need separate accounting treatment for each revenue stream.
- Underestimating substance. The statutory floor (registered office, legal representative, compliance officer and alternate)[26][23] is a floor, not a target: CNAD inspects real substance, and low-substance shells fail the no-objection gate (see Requirements).
- Submitting foreign documents without certified Spanish translation and apostille. All CNAD filings are in Spanish; passports and academic credentials require certified translation and apostille, as do foreign-source corporate documents.
Frequently Asked Questions
LEAD Article 19 covers exchange of digital assets for fiat or other digital assets, operation of a digital-asset or derivative trading platform, risk and price evaluation, underwriting, and placement of digital-asset issuances, structuring, and management of digital-asset investment products, and third-party operations including custody, transfer, order receipt and transmission, and derivative-order execution.
Bitcoin-only services may register only as a Bitcoin Service Provider on the BCR register kept under the Bitcoin Law regulations; multi-asset businesses typically require both a DASP and a BSP registration. The CNAD public registry organises licensees into five activity classes: Risk and Price Evaluators, Structurers, Exchange, Asset Storage and Custody, and Issuances Platforms.
Both options are permitted post the October 2024 LEAD reform. A foreign company may register through a branch in El Salvador (sucursal de sociedad extranjera) or by incorporating a wholly owned Salvadoran S.A. de C.V. The CNAD register has also listed S.A.S. de C.V. registrants since January 2025, so the simplified joint-stock structure has not been excluded in practice. The wholly owned S.A. de C.V. is the cleaner operational design, because a branch complicates local banking and audit. 100% foreign ownership is permitted with no residency requirement for shareholders or directors, and the representative of a Salvadoran S.A. need not be resident, while a branch’s representative must reside permanently in El Salvador; either form needs a compliance officer and an alternate appointed by the board.[27][23]
Two figures, not one. The statutory cost is set by statute and is exact: USD 6,286 to 6,336 in Year 1, being the CNAD initial registration fee of USD 6,132 (fifteen minimum monthly wages in the commerce and services sector, USD 408.80 each since 1 June 2025, payable in USD or BTC within 10 days of a favourable resolution), CNR registry charges of USD 154.26, and USD 50 for each issuance certified. From Year 2 it is the CNAD renewal of USD 4,088 (ten minimum wages) plus USD 142.86 of annual CNR registry charges, USD 4,231 in all.
The build is everything else and is quoted per case: entity formation, legal and advisory work, local representation through a legal representative and a compliance officer with an alternate[26][23], office, and external audit are estimated at USD 47,500 to 144,300 in Year 1 and USD 39,200 to 116,000 a year thereafter. Public-offering authorisations carry an additional 0.01% of offer size, and stablecoin-issuer fees are scaled to planned 12-month issuance volume and sit outside both figures.
The CNAD has up to 20 business days to resolve a complete file.[1][26] Realistic total time from project kickoff to operational status is 3–6 months for standard business models, 7–9 months for complex multi-licence structures or stablecoin issuers. An incomplete file first goes back to the applicant for completion, and each significant change notified before the resolution adds five business days.[1][26]
Banking, document apostille, and pre-registration “objection / no-objection” evaluation sit outside the statutory clock.
Registered Digital Asset Service Providers, certifiers, and issuers are exempt from corporate income tax, capital-gains tax, value-added tax (IVA at 13%), municipal taxes and the obligation to withhold those taxes on revenue derived from Article 19 digital-asset activities. The exemption applies from the notification date of the definitive CNAD registration. Non-Article-19 income (advisory, consulting, fiat-only services) remains subject to the standard 30% corporate income tax (25% if gross taxable income is ≤ USD 150,000).
Bitcoin Service Provider income does not qualify for Article 36 benefits. Article 36(d) extends the exemption to shareholders for dividends paid out of the exempt activity; other dividends carry the ordinary 5% withholding, rising to 25% when the recipient sits in a tax haven or preferential regime.
Local banking is a major operational constraint despite USD legal-tender status since 2001. A traditional Salvadoran retail bank became the first to obtain CNAD DASP registration in October 2024, but broader local-bank appetite remains selective. Neither article 20 of the LEAD nor article 7 of the 2023 DASP Regulation puts a bank account or a bank reference in the registration file, so an account is not a filing prerequisite.[1][26]
Onboarding runs 3–8 weeks on its own clock, so it belongs alongside entity formation rather than after the CNAD resolution. International crypto-friendly Electronic Money Institutions remain the practical instrument for ongoing payment flows; local banks serve as the regulatory anchor and operating-currency account.
In statute, yes. Decreto Legislativo No. 199 of , effective approximately , kept Bitcoin’s legal-tender status (curso legal) but ended compulsory acceptance. Acceptance is now voluntary and private-sector only; the public sector is prohibited from accepting Bitcoin. Articles 4, 8 and 9 of the Bitcoin Law (Bitcoin tax payments, State conversion infrastructure) were repealed; Article 5 (the 0% capital-gains exemption on Bitcoin exchanges) was retained. The IMF Country Report 25/58 of February 2025 describes the reform as having eliminated Bitcoin’s characterisation as currency. The DASP framework under LEAD is unaffected by these changes; the Bitcoin Law amendments apply only to the BSP regime and to public-sector treatment.
A Salvadoran CNAD DASP registration does not grant passporting rights into the EU or EEA. Serving EU clients lawfully requires either reverse solicitation under MiCA Article 61, which is narrow in scope and unsuitable as a marketing strategy, or holding a separate MiCA CASP authorisation in an EU jurisdiction (for example Lithuania, Ireland, France, or Malta). One structure for clients targeting both LatAm and Europe is a CNAD DASP for the LatAm operation and a separate MiCA CASP for European market access, with appropriate intercompany arrangements between the two regulated entities. See the full reverse solicitation guide for detail.
Tokenised real-world assets can use the CNAD digital-asset offering regime. This is separate from a DASP service registration and from ordinary securities authorisation: LEAD Article 3 states that digital assets are not títulos valores and excludes the listed securities-law regimes. Classify the token, offering and vehicle before applying; a fund structure needs its own analysis.[1] See our fund licensing guidance.
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References
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- Comisión Nacional de Activos Digitales (CNAD), Digital Assets Issuance Law (Ley de Emisión de Activos Digitales, Decreto Legislativo No. 643), including arts. 12 (initial registration fee of fifteen, and annual renewal of ten, minimum wages in the commerce and services sector), 18(d) (a foreign legal person registers through a sociedad anónima or a branch domiciled in El Salvador), 19 (digital-asset services), 20 (registration requirements; up to 20 business days to resolve once the required information is filed; five business days to complete an incomplete application), 21(h) (adequate financial and non-financial resources as the Commission sets) and 36 (tax treatment; under 36(d) the benefits extend to shareholders for dividends from the exempt activity), cnad.gob.sv, accessed .
- CNAD, Public Registry of Digital Asset Service Providers (86 providers on the All tab and one more listed only in the category tabs, numbered PSAD-0001 to PSAD-0097; latest registration 16 September 2026; S.A.S. de C.V. registrants from 6 January 2025; Banco Atlántida El Salvador, PSAD-0035, 30 October 2024), cnad.gob.sv, accessed .
- CNAD, Digital Assets Issuance Law (LEAD), Decreto Legislativo No. 643 (English translation), cnad.gob.sv, accessed .
- CNAD, 2023–2024 Annual Report, cnad.gob.sv, accessed .
- CNAD, El Salvador with the Best Crypto Regulation in Latin America, cnad.gob.sv, accessed .
- CoinDesk, El Salvador’s Top Crypto Regulator Meets With U.S. SEC, , coindesk.com, accessed .
- CNAD, Register as Digital Assets Service Provider (DASP) (20 business days to resolve; 10 business days to complete an incomplete file; initial registration fee shown as USD 5,475), cnad.gob.sv, accessed .
- Asamblea Legislativa de la República de El Salvador, Decreto Legislativo No. 199 (Bitcoin Law reform, 29 January 2025; art. 1: Bitcoin keeps curso legal with voluntary acceptance by private persons only; art. 7 repeals arts. 4, 8 and 9; in force ninety days after publication in Diario Oficial No. 21, Tomo 446), asamblea.gob.sv, accessed .
- International Monetary Fund, El Salvador Country Report No. 25/58 (February 2025), imf.org, accessed .
- CNAD, First Registered Stablecoin Issued and Regulated in El Salvador, cnad.gob.sv, accessed .
- Banco Central de Reserva de El Salvador, Normas Técnicas para Facilitar la Participación de las Entidades Financieras en el Ecosistema Bitcoin (NRP-29), arts. 1, 2, 3(f) and 10 (as amended on 30 May 2025 and 10 November 2025, in force 25 November 2025), bcr.gob.sv, accessed .
- PwC Worldwide Tax Summaries, El Salvador Corporate Taxes (last reviewed 26 February 2026), taxsummaries.pwc.com, accessed .
- International Monetary Fund, Press Release No. 25/440, IMF Staff Statement on El Salvador (22 December 2025), imf.org, accessed .
- GAFILAT, El Salvador Mutual Evaluation Report 2024 (on-site 8 to 19 January 2024; adopted at the XLIX Plenary, August 2024), gafilat.org, accessed .
- International Monetary Fund, IMF Executive Board Approves New 40-month US$1.4 billion Extended Fund Facility Arrangement for El Salvador, Press Release No. 25/043, , imf.org, accessed .
- International Monetary Fund, Country Report No. 25/190, First Review Under the EFF (June 2025), elibrary.imf.org, accessed .
- CNAD, Legal Framework, cnad.gob.sv, accessed .
- Banco Central de Reserva, BSP Registry Portal, registrobitcoin.bcr.gob.sv, accessed .
- Bitfinex, Bitfinex Secures Licence in El Salvador (12 May 2026), blog.bitfinex.com, accessed .
- Tether, Tether Licensed in El Salvador (13 January 2025), tether.io, accessed .
- Asamblea Legislativa de El Salvador, Decreto Legislativo No. 957 (14 December 2011; Diario Oficial No. 235, Tomo 393), art. 5, replacing article 41 of the Ley de Impuesto sobre la Renta (30% applied to the renta imponible; 25% for taxpayers whose rentas gravadas do not exceed USD 150,000), asamblea.gob.sv, accessed .
- Financial Action Task Force (FATF), Jurisdictions under Increased Monitoring – 19 June 2026 and High-Risk Jurisdictions subject to a Call for Action – June 2026 (El Salvador on neither list), fatf-gafi.org, accessed (archived copy of 22 September 2026).
- Asamblea Legislativa de El Salvador, Decreto No. 426: Ley Especial para la Prevención, Control y Sanción del Lavado de Activos, Financiamiento al Terrorismo y de la Proliferación de Armas de Destrucción Masiva, Diario Oficial No. 190, Tomo 449, (articles 20, 25, 60 and 61), asamblea.gob.sv, accessed .
- Banco Central de Reserva de El Salvador, Registro de Proveedores de Servicios de Bitcoin: proveedores registrados (300 entries, 23 suspended; the register states that authorisation to operate is issued by the Comisión Nacional de Activos Digitales), registrobitcoin.bcr.gob.sv, accessed .
- Republic of Costa Rica, Ley 10961 (adds Article 15 quater to Law 7786: virtual-asset service providers register with SUGEF; registration is not an authorisation to operate; in force three months after publication), La Gaceta, Alcance 78, , imprentanacional.go.cr, accessed .
- Comisión Nacional de Activos Digitales (CNAD), Reglamento de Proveedores de Servicios de Activos Digitales (2023), arts. 7 (the registration file, listing no bank account or bank reference; (b)(ii) registered board or sole-administrator credential, or a general power to represent the company before public bodies), 8 (up to 20 business days from receipt to resolve the application or to notify that it is incomplete; 10 business days to complete an incomplete one; information requests before the deadline with a stated reply period) and 9 (5 further business days per significant change notified), cnad.gob.sv, accessed .
- Asamblea Legislativa de El Salvador, Código de Comercio, arts. 260 (representation of an S.A. by its sole director or board president, with no residency condition) and 358(c) (the representative of a foreign company’s branch must reside permanently in El Salvador), asamblea.gob.sv, accessed .
- Ministerio de Trabajo y Previsión Social, Decreto Ejecutivo No. 11: Tarifas de salarios mínimos para la República de El Salvador (22 May 2025; art. 2: commerce and services USD 408.80 a month; art. 15: in force 1 June 2025), jurisprudencia.gob.sv, accessed .
- Asamblea Legislativa de El Salvador, Ley de Registro de Comercio (Decreto No. 271), arts. 63 (matrícula USD 91.43 in the first asset band, renewed annually; USD 34.29 per local, charged again on each renewal), 64 (renewal in the month of the company’s inscription), 66 (inscription of the constitution deed at USD 0.57 per USD 100 of capital) and 71 (USD 17.14 for depositing the initial or year-end balance sheet), asamblea.gob.sv, accessed .
- CNAD, Public Registry: Issuers of Public Offerings of Stablecoins (EME-0001 and EME-0002, Moon Gold El Salvador and Moon Gold NA, registered 20 June 2024; five stablecoin issuers listed, the latest on 28 April 2026), cnad.gob.sv, accessed .
- Fiscalía General de la República, Instructivo de la Unidad de Investigación Financiera para la Prevención del Lavado de Dinero y de Activos (Acuerdo No. 380, 22 October 2021; D.O. No. 205, 27 October 2021; amended by Acuerdos No. 266 and No. 476 of 2023), cash transactions above USD 10,000, other means above USD 25,000, international transfers of USD 1,000 or more, uif.gob.sv (read from the archived copy of 24 September 2026), accessed .
- Asamblea Legislativa de El Salvador, Decreto No. 641: Reformas al Código de Comercio, arts. 26–27 (replacing Commercial Code arts. 192 and 194: subscribed capital, initial contributions and the one-year payment deadline), asamblea.gob.sv, accessed .