Argentina now requires every provider of virtual‑asset services to register with the Comisión Nacional de Valores (CNV) before it may lawfully operate. Since Law 27,739 was published on 15 March 2024 and the CNV followed with implementing rules RG 994/2024 and the more detailed RG 1058/2025 VASP registration in Argentina has moved from regulatory theory to operational reality. The CNV’s PSAV registry is open, supervision is active, and unregistered operators face administrative fines, URL blocking, and referral to prosecutorial authorities.
This guide explains who must register, what documents and controls the CNV expects, how the Unidad de Información Financiera (UIF) AML framework applies, what foreign VASPs must do, and realistic timelines and costs. Whether you are a crypto exchange, fintech founder, compliance officer, in‑house counsel, or investor evaluating Argentina, this page provides a single, practitioner‑focused resource. For a quick compliance triage, download the CNV VASP Registration Checklist (PDF) referenced throughout this article.
Who Must Register as a VASP with the CNV
Definition of PSAV / VASP Under Law 27,739
Law 27,739 amended Argentina’s anti‑money‑laundering statute and introduced the concept of a Proveedor de Servicios de Activos Virtuales (PSAV) the local equivalent of the FATF “Virtual Asset Service Provider.” A PSAV is any natural or legal person that, as a business or on behalf of a customer, carries out one or more of the regulated activities listed below. The statutory definition captures both residents and non‑residents that direct services toward Argentine customers.
Activities That Trigger Registration
Under Law 27,739 and the CNV’s implementing resolutions, five categories of activity trigger the obligation to register on the CNV PSAV registry:
- Exchange of fiat currency for virtual assets (and vice versa) on‑ and off‑ramps, whether via bank transfer, card, or cash.
- Exchange of one virtual asset for another crypto‑to‑crypto trading desks and automated market makers.
- Transfer of virtual assets transmitting virtual assets on behalf of customers, including remittance‑style services.
- Custody and/or administration of virtual assets holding private keys or controlling access on behalf of third parties, including institutional custody solutions.
- Participation in or provision of services related to the issuance, offer, or sale of virtual assets token launches, initial coin offerings, and distribution platforms.
Any entity performing even one of these activities as a regular business directed at Argentine customers must apply for inclusion in the PSAV registry maintained by the CNV.
De Minimis Threshold and Exceptions
CNV RG 994/2024 introduced a de minimis threshold: individuals or entities whose aggregate monthly virtual‑asset activity does not exceed UVA 35,000 (approximately ARS 35 million at current UVA values, though this fluctuates with the index) are not required to register. Activity is measured on an aggregate basis across all five activity categories. Entities that cross this threshold in any given month trigger the registration obligation and must apply without delay.
Resident vs Non‑Resident Exposure
Non‑resident entities are not exempt. When a foreign platform actively solicits Argentine users, accepts Argentine‑peso deposits, or maintains marketing or operational infrastructure directed at Argentina, it falls within the scope of Law 27,739. See the Foreign VASP Rules section below for practical options.
Step‑by‑Step CNV VASP Registration Application
Follow these numbered steps to prepare and file a CNV PSAV registration. Each step should be documented and retained as evidence of compliance readiness.
- Pre‑assessment and eligibility check. Map every virtual‑asset activity the business performs or plans to perform against the five statutory triggers. Estimate monthly aggregate volumes against the UVA 35,000 de minimis threshold. Confirm the entity’s corporate form is compatible with CNV requirements (typically a sociedad anónima, SRL, or registered branch of a foreign entity). This step avoids unnecessary filings or, conversely, identifies activities the applicant may not have realised trigger registration.
- Corporate documentation and company requirements. Assemble the entity’s certificate of incorporation (or equivalent foreign instrument), current bylaws, CUIT (Argentine tax identification number), proof of current tax standing from AFIP, and board minutes authorising the entity to carry out PSAV activities. Foreign entities must provide apostilled and officially translated versions of each document.
- Capital and solvency evidence. RG 1058/2025 sets minimum net‑worth and capital‑integration rules. Prepare an auditor’s certificate confirming the entity meets the required capital level, together with bank statements or escrow evidence showing capital integration. Capital must be paid in and available mere subscriptions do not satisfy the requirement.
- Governance and operational arrangements. The CNV expects a clear governance framework: an identified board or managing body, a designated AML compliance officer (Oficial de Cumplimiento), documented internal controls, and evidence of segregation of client assets from the entity’s own funds. Custody models (self‑custody, third‑party custodian, or hybrid) must be described and supported by operational flowcharts and contractual arrangements.
- AML/KYC programme and SAR/STR reporting setup. Prepare a comprehensive AML manual aligned with UIF Resolution 49/2024. The manual must cover customer due diligence (CDD), enhanced due diligence (EDD) for high‑risk categories, suspicious‑activity reporting (SAR) procedures, record‑keeping, staff training, and the internal escalation chain. Ensure the entity is registered or ready to register as a Sujeto Obligado with the UIF within 30 days of commencing activity.
- Technology, custody, and record‑keeping evidence. The CNV requires detailed evidence of the entity’s technology stack: transaction logs with date/time (to the second), quantity, asset type, internal transaction ID or blockchain TXID, and linked client ID. Order‑book snapshots, cold‑ and warm‑wallet custody controls, multi‑signature governance, and disaster‑recovery procedures should be documented and ready for submission.
- Outsourcing, third‑party providers, and vendor due diligence. If the applicant relies on external custody providers, wallet‑infrastructure vendors, or KYC verification services, each relationship must be disclosed. Prepare vendor due‑diligence files including contracts, sub‑processor data‑flow diagrams, and confirmation that the vendor’s own AML controls meet Argentine standards.
- Local presence / branch structure decision (foreign entities). Foreign applicants must decide whether to register as a non‑resident entity or establish a local subsidiary or branch. The choice has implications for tax, liability, and ongoing CNV supervision. See the Foreign VASP Rules section for a comparative analysis.
- Preparing the CNV application form via TAD. The application is filed through the CNV’s TAD (Trámites a Distancia) platform. Assemble all annexes, sworn statements (declaraciones juradas), and contact‑point details in the required format. Cross‑check every item against the documentation checklist below before submission.
- Post‑filing compliance steps. After filing, monitor TAD for CNV clarification requests and respond within the prescribed deadline. Once registration is granted, comply with ongoing reporting obligations, pay applicable CNV fiscalisation fees on the schedule set by RG 1058, and update the registry promptly if corporate details, beneficial owners, or operational models change.
Documentation Checklist
The following checklist mirrors the downloadable CNV VASP Registration Checklist (PDF):
- Certificate of incorporation / bylaws current, certified copy (apostilled if foreign).
- CUIT and AFIP tax compliance certificate confirming active status and no outstanding tax debt.
- Board minutes authorising PSAV activities and designating the compliance officer.
- Identification documents of directors, beneficial owners (UBOs), and the AML officer.
- Auditor’s capital‑integration letter confirming minimum net worth per RG 1058.
- AML/KYC manual compliant with UIF Res. 49/2024; includes CDD, EDD, SAR procedures, and training plan.
- Technology and custody evidence architecture diagrams, transaction‑log samples, cold/warm wallet policies.
- Beneficial‑ownership register full chain to ultimate natural persons.
- Proof of segregation of client assets bank account or custody‑account evidence; reconciliation procedures.
- Privacy and sanctions policies data‑protection policy, sanctions‑screening methodology.
- Vendor due‑diligence files contracts and compliance certifications for outsourced services.
- If foreign: apostilles, legal opinions, and power of attorney covering parent entity, authorised local representative, and translated corporate documents.
AML Obligations and Thresholds for VASPs in Argentina
UIF Subject‑Obliged Status
Under UIF Resolution 49/2024, every registered PSAV automatically acquires the status of Sujeto Obligado (Subject Obliged) before Argentina’s financial‑intelligence unit. PSAVs that were already operating when the resolution entered into force were required to register with the UIF within 30 days. Failure to do so exposes the entity to separate UIF sanctions, independent of any CNV enforcement action.
KYC / CDD Requirements
PSAVs must apply customer due diligence at onboarding and on an ongoing basis. Three tiers apply:
- Simplified CDD permitted for low‑value, low‑risk customers below defined transaction thresholds.
- Standard CDD identity verification, source‑of‑funds assessment, beneficial‑ownership identification.
- Enhanced due diligence (EDD) mandatory for politically exposed persons (PEPs), customers from high‑risk jurisdictions (FATF grey/black lists), and transactions above elevated monetary thresholds. Chain‑analysis evidence is expected where blockchain transactions are involved.
Reporting Thresholds and CTR/SAR Triggers
VASP AML obligations in Argentina include filing suspicious‑activity reports (SARs) with the UIF whenever the entity identifies unusual or suspicious conduct there is no monetary floor for SARs. In addition, systematic reports (similar to currency‑transaction reports) must be filed for transactions exceeding prescribed UVA‑denominated thresholds. Aggregation rules apply: multiple transactions by the same customer within a reporting period are combined. Record‑keeping obligations require PSAVs to retain all CDD and transaction records for a minimum of ten years.
Transaction Monitoring and Blockchain Evidence
The CNV expects PSAVs to maintain transaction logs containing, at a minimum: date and time (with seconds), quantity, asset type, internal transaction ID or blockchain TXID, and the corresponding client ID. These records must be producible on demand for audits and should be reconciled against on‑chain data. Automated transaction‑monitoring systems including blockchain‑analytics tools are considered best practice and, in high‑volume operations, a practical necessity.
Sanctions, Asset Freezes, and UIF/CNV Coordination
The UIF and CNV coordinate on enforcement. Either regulator may request information from a PSAV, and the UIF may order the immediate freezing of assets linked to suspected money laundering or terrorism financing. Administrative measures available to the CNV include fines, suspension, and de‑registration in addition to referral to criminal‑prosecution authorities.
Foreign VASP Rules
Do Foreign VASPs Need a Local Branch or Local Company?
Foreign VASPs directing services at Argentine customers have two principal options under CNV rules:
- Option A Register as a foreign entity that carries out PSAV activity in Argentina. This path requires designating a local representative, complying with all Argentine AML/KYC rules, and paying applicable CNV fees as specified in RG 1058.
- Option B Establish a local subsidiary or registered branch and transfer Argentine‑facing operations to that entity. This approach simplifies ongoing compliance, particularly for supervision, dispute resolution, and tax obligations.
CNV interpretative guidance (CRI) clarifies that fee‑payment obligations and supervision timelines apply equally to both options. In practice, most foreign VASPs with significant Argentine customer volumes opt for a local subsidiary to reduce regulatory friction.
Practical Checklist for Foreign VASPs
- Apostilled and translated corporate documents certificate of incorporation, bylaws, and good‑standing certificate of the parent entity.
- Power of attorney appointing a local representative authorised to act before the CNV and UIF.
- Legal opinions confirming the entity’s good standing and compliance with its home‑jurisdiction regulations.
- Accounting certification of capital demonstrating the parent entity (or local branch) meets RG 1058 minimum capital requirements.
- Proof of parent company ownership and compliance controls group structure chart, UBO register, and group AML policy.
Cross‑Border AML Considerations
Argentine law applies the “principle of greater rigour”: when the foreign parent’s home‑jurisdiction AML rules are less strict than Argentina’s, the Argentine standard prevails for all customer accounts located in Argentina. Foreign VASPs must ensure their local AML manual, CDD thresholds, and SAR processes meet UIF requirements, regardless of what the parent‑company programme provides.
Timeline and Fees for VASP Registration in Argentina
Typical CNV Processing Timeline
- Preparation phase: 2–8 weeks, depending on audit readiness, capital integration, and technology remediation.
- CNV initial review: 4–12 weeks from filing; the CNV may request clarifications or additional documentation.
- Final decision and registration: 2–6 weeks after the applicant’s final reply to CNV queries.
- Total typical project: 8–26 weeks from project kick‑off to registration, with significant variability based on the complexity of the applicant’s operations and responsiveness to CNV requests.
Fees and Tax Considerations
RG 1058/2025 establishes a fiscalisation‑fee regime for registered PSAVs. Fee amounts and payment timings are set by the CNV and published periodically. Applicants should also budget for professional costs (legal counsel, auditors, technology consultants) and, if applicable, corporate set‑up costs for a local subsidiary or branch.
Comparison Table: Requirements, Timeline, and Typical Costs
| Requirement |
Typical CNV Timeline (from filing) |
Typical Professional & Set‑Up Cost (indicative) |
| Local registration (domestic company ready) |
8–12 weeks |
USD 5,000–20,000 (legal + admin + tech remediation) |
| Foreign VASP registering as non‑resident |
10–20 weeks |
USD 8,000–35,000 (legal opinions, translations, apostilles) |
| Complex custody / bespoke tech evidence |
+4–12 weeks |
USD 10,000–50,000 (audit, forensics, crypto‑tech work) |
Note: costs are indicative professional estimates covering local counsel, audits, and technology fixes. Consult the CNV’s published fee schedule under RG 1058 for official fiscalisation‑fee amounts.
Key Requirements and Eligibility Checklist
Corporate Form and Registration Evidence
Applicants must hold a valid CUIT, provide a current certificate of incorporation, and disclose all beneficial owners down to the ultimate natural person. The entity’s corporate purpose must include or be amended to include the provision of virtual‑asset services.
Minimum Capital / Net Worth and Proof of Integration
RG 1058/2025 prescribes minimum capital and net‑worth thresholds. Proof of integration must be evidenced by an independent auditor’s letter and supporting bank statements. Capital must be paid in, not merely subscribed.
Directors and Management Fit‑and‑Propriety Checks
Each director, manager, and the designated AML officer must submit identification documents, background‑check authorisations, and sworn statements regarding criminal or regulatory history. The CNV may request additional information on any individual.
Internal Controls and Governance
The entity must designate an AML compliance officer, maintain a documented compliance function, establish KYC and SAR‑reporting processes, and implement a staff‑training programme. All policies must be current and reviewed at least annually.
Operational Controls
Segregation of client funds from proprietary funds is mandatory. The entity must describe its custody model, produce reconciliation procedures, and demonstrate that client assets are protected against insolvency of the PSAV. Use the downloadable CNV VASP Registration Checklist (PDF) to tick each required document and policy before filing.
Client Case Studies
- Case A Domestic exchange: rapid remediation and registration. A mid‑sized Argentine exchange lacked formal asset‑segregation controls and a written AML manual. Working with a GLE partner, the entity remediated its policies, conducted transaction‑log audits, and filed its CNV application. Registration was granted in 10 weeks.
- Case B Foreign wallet provider: branch vs registration choice. A European wallet operator was uncertain whether to register as a non‑resident or open a local subsidiary. A comparative analysis recommended establishing a local subsidiary for regulatory simplicity and tax efficiency. Corporate documentation was prepared and CNV registration completed within 16 weeks.
- Case C Custodian integration: tech evidence and blockchain reconciliation. An institutional custodian could not produce TXID tracebacks required by the CNV. Forensic logging remediation was implemented, reconciliation procedures were documented, and the evidence was accepted by the CNV with minor conditions imposed.
Downloadable Checklist and Template (PDF)
The CNV VASP Registration Checklist & Document Template (PDF) is a single‑page compliance‑triage tool with an appendix containing sample AML‑policy headings, sample sworn‑statement language, and a TAD submission bundle checklist. It mirrors the documentation list in the Step‑by‑Step Application section above and is designed for internal project planning, counsel briefings, and final pre‑submission review.
To receive the checklist, use the download button provided on this page. The PDF is maintained and updated to reflect the latest CNV and UIF guidance.
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