Argentina Crypto License

What Is a PSAV?

A PSAV is a person or company that performs one or more specified virtual-asset services as a business for, or on behalf of, another person. The term stands for Proveedor de Servicios de Activos Virtuales, which translates as Virtual Asset Service Provider. Under Argentine law, the classification depends on what the provider actually does, rather than whether the company describes itself as an exchange, wallet, crypto fintech, trading platform or infrastructure provider. (Law No. 25,246, Section 4 bis, incorporated by Law No. 27,739, Section 4.)

The Statutory Origin of the PSAV Regime

Argentina introduced the current PSAV framework through Law No. 27,739, enacted in March 2024. The law amended Law No. 25,246 by adding statutory definitions of "virtual asset" and "virtual asset service provider," creating the PSAV registry administered by the CNV and replacing Section 20 of Law No. 25,246 to include PSAVs as obligated entities under item 13. (Law No. 27,739, Sections 4, 14 and 37.)

The statutory definition of a virtual asset covers a digital representation of value that can be digitally traded or transferred and used for payment or investment purposes. It expressly excludes legal tender in Argentina and currencies issued by foreign countries or jurisdictions. This means that Bitcoin, Ether, stablecoins and many other transferable digital assets can fall within the definition, while Argentine pesos and foreign fiat currencies do not become virtual assets merely because they are held or transferred electronically. Whether a particular token qualifies must still be examined according to its legal and functional characteristics. (Law No. 25,246, Section 4 bis, as incorporated by Law No. 27,739, Section 4.)

Law No. 27,739 assigns two related functions to the CNV. First, the CNV must maintain adequate, accurate and current information concerning persons that qualify as PSAVs. Second, it may exercise its statutory powers of supervision, regulation, inspection, enforcement and sanction over those providers. The law also requires the CNV to regulate PSAV activities according to principles that include user protection, information security, personal data protection, operational security, solvency, transparency, corporate governance, risk-based controls and prevention of money laundering, terrorist financing and proliferation financing. (Law No. 27,739, Sections 37 and 38.)

The CNV initially created the registry through General Resolution No. 994/2024. It subsequently replaced that initial registration framework with General Resolution No. 1058/2025, which became the central operating rule for PSAVs. General Resolution No. 1058/2025 regulates the registration perimeter, foreign-provider nexus, exclusions, registry categories, corporate structure, minimum net worth, internal governance, information systems, cybersecurity, custody, customer assets, disclosures, complaints, advertising, outsourcing, reporting and enforcement consequences. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III.)

PSAV and VASP

PSAV is the Argentine equivalent of the internationally used term VASP, or Virtual Asset Service Provider. The Argentine statutory definition follows the same five core activities used by the Financial Action Task Force, or FATF: exchange between virtual assets and fiat currencies, exchange among virtual assets, transfers, safekeeping or administration, and financial services connected with an issuer's offer or sale of a virtual asset. (Law No. 25,246, Section 4 bis; FATF Glossary, "Virtual Asset Service Providers.")

This equivalence is useful for foreign groups because an exchange, custodian or wallet provider already treated as a VASP in another country will often recognize the basic structure of the Argentine definition. It does not follow, however, that a foreign VASP authorization determines the company's Argentine status. Argentina applies its own activity tests, territorial connections, exclusions, corporate requirements and registry categories. A company may therefore be authorized abroad and still need a separate Argentine structure and CNV registration before carrying out covered activities in Argentina. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1, 3, 6 and 8.)

The Argentine definition is activity-based. A provider falls within the statutory concept when it conducts at least one covered activity as a business for, or on behalf of, another person. By contrast, General Resolution No. 1058/2025 excludes persons trading virtual assets solely for their own account, businesses that merely accept or deliver virtual assets as payment for their own goods or services, decentralized protocols without an identifiable service provider and providers acting exclusively as self-custody wallet providers. These exclusions are fact-sensitive. In particular, calling a wallet "self-custodial" or a protocol "decentralized" will not control the result when an identifiable operator retains effective control over assets, keys, transactions or the provision of the service. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1.)

Why "Crypto License" Is Useful but Technically Inexact

Argentina does not issue a statutory authorization formally called a "crypto license." The legislation creates a Registro de Proveedores de Servicios de Activos Virtuales, and the legally correct requirement is registration as a PSAV with the CNV. Covered providers must obtain that registration before performing PSAV activities in Argentina. (Law No. 27,739, Section 37; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 2.)

The expression "Argentina crypto license" remains useful because it describes the practical question foreign companies are asking: what regulatory authorization is required to offer crypto services in Argentina? The answer is PSAV registration, together with the corporate, operational and AML arrangements required to obtain and maintain it. The distinction should prevent a common misunderstanding. "Registration" does not mean that the applicant merely submits its name, ownership details and contact information to a public list.

General Resolution No. 1058/2025 requires the applicant to demonstrate that it has an eligible corporate structure, the required financial resources, identified authorities and beneficial owners, suitable operational manuals, information systems, internal controls, cybersecurity arrangements, custody procedures where applicable, customer-protection mechanisms and the ability to comply with ongoing reporting duties. These requirements continue after registration and may be examined through the CNV's supervisory powers. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6 and 9 to 40.)

Registration Is a Substantive Review

CNV General Resolution No. 1139/2026 confirms that access to CNV registries depends on a substantive assessment rather than automatic acceptance of a filing. For PSAVs, the CNV applies the integrity and solvency standards established by the resolution, subject to the specific transitional exception that currently excludes the idoneity requirement applicable under Section 11(1) of the new regime. The CNV may assess the applicant, its directors, administrators and other persons performing management functions, while beneficial owners are assessed for integrity. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Sections 6 to 12; Title XVIII, Chapter X, Section 4.)

Integrity review includes criminal and regulatory background, AML declarations, politically exposed person status and screening against applicable terrorism-related lists. Solvency review may consider unjustified defaults, adverse commercial records, economic judgments, bankruptcy proceedings, attachments and similar evidence relevant to prudent financial administration. These conditions must be preserved after registration, and loss of the conditions supporting the authorization can result in expiration of the registration. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Sections 11 and 12.)

The PSAV registry should therefore be treated as an authorization process in substance, even though Argentine law uses the term registration. The applicant must show that its legal entity, ownership, management, financial position, systems, operating model and compliance program meet the applicable standards. The registration project begins with regulatory classification, but it ultimately requires the company to present a functioning and internally consistent operating model to the CNV.

What the PSAV Regime Regulates

The CNV's PSAV jurisdiction primarily regulates service providers and the manner in which they conduct covered activities. It does not make every virtual asset a security or place every token under the capital-markets regime. General Resolution No. 1058/2025 expressly states that the CNV's authority under Law No. 27,739 concerns PSAV activities and does not extend to regulation of virtual assets themselves unless the relevant asset also falls within the definition of a security under Section 2 of Law No. 26,831. (CNV General Resolution No. 1058/2025, recitals; Law No. 26,831, Section 2.)

This distinction has two consequences. First, PSAV registration does not amount to regulatory approval of each asset listed, transferred or held through the platform. Second, a product involving tokenized securities, investment contracts, collective investment structures or public offerings may trigger capital-markets rules in addition to the PSAV regime. The relevant question is therefore broader than whether the company handles crypto: the legal analysis must identify the service being provided, the characteristics of the asset and any additional financial activity built into the product. Our guide to fintech regulation in Argentina maps those neighboring regimes.

Who Must Register?

A company must register as a PSAV when it performs at least one of the five regulated virtual-asset activities as a business for, or on behalf of, another person and the activity falls within Argentina's territorial scope. For an Argentine company, performing a covered activity is enough to trigger the registration requirement. For a foreign company, the analysis has two stages: the company must perform a covered activity and at least one of the territorial connections established by CNV General Resolution No. 1058/2025 must be present. (Law No. 25,246, Section 4 bis; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 3.)

The Basic Activity Test

The statutory test asks what service the company provides, whether it provides that service as a business, and whether it acts for or on behalf of another person. A company does not need to describe itself as an exchange or wallet, hold a financial license abroad, charge a separate transaction fee, or maintain a physical office in Argentina to perform a PSAV activity. The classification follows the actual functions performed within the product and the contractual relationship with the customer. (Law No. 25,246, Section 4 bis, incorporated by Law No. 27,739, Section 4.)

The words "as a business" distinguish a service provider from a person dealing with virtual assets solely for its own account. The requirement that the activity be performed for or on behalf of another person directs the analysis toward the customer-facing service. A group should therefore map each material function separately, including which entity contracts with the customer, receives fiat or virtual assets, controls the relevant accounts or wallets, executes transactions, determines whether an instruction will be processed and bears responsibility for delivery. A contractual statement that an entity is a technology provider will carry limited weight if its actual role includes performing a regulated service.

The law establishes five covered activities: (a) exchange between virtual assets and fiat currencies; (b) exchange between one or more forms of virtual assets; (c) transfer of virtual assets; (d) custody or administration of virtual assets or instruments permitting control over them; and (e) participation in, or provision of, financial services related to an issuer's offer or sale of a virtual asset. Performing any one of them may be sufficient. (Law No. 25,246, Section 4 bis; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8.)

Exchange Between Virtual Assets and Fiat Currency

A business falls within the first activity when it exchanges virtual assets for legal tender or legal tender for virtual assets on behalf of customers. Typical examples include a centralized exchange offering Argentine pesos or foreign currency pairs, an OTC desk buying and selling stablecoins for customers, a broker arranging fiat-to-crypto conversions, or a platform that receives fiat funds and delivers virtual assets as part of its service. Fiat currency includes Argentine pesos and currencies issued by foreign countries or jurisdictions. (Law No. 25,246, Section 4 bis; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 1.)

The analysis does not depend solely on whether the provider acts as agent or principal in the trade. A company that regularly purchases virtual assets from customers or sells virtual assets to them as its commercial service may still be conducting exchange activity for those customers. By contrast, a company does not become a PSAV merely because it accepts virtual assets as payment for its own goods or services, or delivers virtual assets as consideration for goods or services that it itself purchases. General Resolution No. 1058/2025 expressly excludes that merchant-payment situation, regardless of amount. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1(ii).)

This distinction matters for stablecoin payment products. A merchant accepting USDC for its own products is situated differently from an intermediary that receives the customer's pesos, converts them into USDC and transfers the USDC to the merchant or another beneficiary. The first case may fall within the merchant exclusion. The second requires separate analysis of exchange and transfer activities, even when the conversion is embedded in a broader payment flow.

Exchange Between Virtual Assets

The second activity covers the exchange of one virtual asset for another. A platform offering BTC/ETH, USDC/USDT or other crypto-to-crypto pairs may fall within the PSAV perimeter even if it never accepts Argentine pesos, US dollars or any other fiat currency. The absence of a fiat leg does not remove the activity from the statutory definition. (Law No. 25,246, Section 4 bis(ii); CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 2.)

This category may apply to order-book exchanges, request-for-quote systems, brokerage models, swap functions and peer-to-peer platforms where the provider creates the commercial environment in which customers exchange virtual assets. UIF Resolution No. 49/2024 expressly defines peer-to-peer transfers for AML purposes as direct exchanges between users, involving fiat currency or other virtual assets, where the parties contact each other in a secure environment developed by a PSAV. That definition supports treating operation of the transaction environment as a regulated function even when users are the direct counterparties to each other. (UIF Resolution No. 49/2024, Section 2(x).)

Whether the trade settles through an on-chain transaction or through entries in the provider's internal ledger should not be treated as determinative by itself. The relevant issue is whether the provider offers and operates the exchange service for customers. The architecture used to settle the trade affects custody, recordkeeping and AML obligations, but it does not necessarily change the economic function being performed.

Transfers of Virtual Assets

The third activity is the transfer of virtual assets for or on behalf of another person. It can apply where a provider receives, transmits or executes a customer instruction that moves virtual assets from one wallet, address or customer account to another. (Law No. 25,246, Section 4 bis(iii); CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 3.)

A transfer service may be offered independently or combined with exchange or custody. For example, a hosted wallet may hold a customer's assets and permit withdrawals to an external address. A remittance product may receive one virtual asset, transmit value across borders and deliver the same or a different asset to the beneficiary. A payment platform may convert fiat currency into a stablecoin and transfer it to another user. Each function must be classified separately because the same flow may place the provider in more than one registry category.

The fact that the underlying blockchain processes the final transaction does not necessarily mean that the provider performs no transfer service. The relevant questions include whether the company receives the instruction, authenticates it, determines whether it may proceed, selects or controls the sending wallet, signs or causes the transaction to be signed, and can delay, reject or reverse an internal ledger movement. These factors are especially relevant when the company controls an omnibus wallet or maintains customer balances off-chain.

UIF Resolution No. 49/2024 also imposes travel-rule requirements on covered transactions and requires PSAVs to identify the originator and beneficiary under the applicable international standards and the exchange mechanism established by the UIF. The AML treatment does not itself determine whether a product falls within Category 3, but it confirms that transfer functionality is regulated as a distinct operational and compliance risk. (UIF Resolution No. 49/2024, Section 37.)

Custody and Administration

The fourth activity covers custody or administration of virtual assets or instruments that permit control over them. It reaches providers that hold customer virtual assets, control private keys, administer signing arrangements, or otherwise possess the practical ability to authorize or prevent transactions involving customer assets. (Law No. 25,246, Section 4 bis(iv); CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 4.)

The CNV expressly excludes providers acting exclusively as providers of self-custody wallets. UIF Resolution No. 49/2024 defines a self-custodied wallet as software that permits interaction with a blockchain address while the user remains responsible for securing the private keys and retains control over the virtual assets. The exclusion therefore depends on actual control, rather than the product label used in the terms of service. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1(iv); UIF Resolution No. 49/2024, Section 2(e).)

A wallet may require Category 4 registration when the provider can unilaterally or jointly sign transactions, recover or replace credentials, freeze withdrawals, move assets without a new customer signature, or control enough components of an MPC or multisignature arrangement to determine the disposition of the assets. Outsourcing key storage to another custodian does not automatically remove the customer-facing provider from the custody analysis. General Resolution No. 1058/2025 expressly contemplates custody performed through a third party and subjects registered custodians to asset-segregation and prudential requirements. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 15 to 19.)

The harder cases involve technical architectures in which the customer and provider each control part of the signing process. The legal question should be framed in operational terms: who can cause a transaction to occur, who can block it, what happens if one participant refuses to cooperate, who can reconstruct or replace key material, and whether the customer can move the assets without the provider. A claim of non-custodial status should be tested against the system design, recovery procedures and contractual allocation of control.

Services Related to an Issuer's Offer or Sale

The fifth activity covers participation in, and provision of, financial services related to an issuer's offer or sale of a virtual asset. General Resolution No. 1058/2025 places within Category 5 providers that offer platforms or mobile applications to issuers for initial virtual-asset offerings or use their service as a public means of raising funds to finance the issuer's projects. The mere act of issuing a virtual asset is expressly excluded from this category. (Law No. 25,246, Section 4 bis(v); CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 5.)

The distinction is between the issuer's creation of its own asset and the provision of an offering or financial intermediation service around that issuance. A token issuer does not become a Category 5 PSAV solely by minting or issuing the token. A platform that structures or operates the public sale, receives investor funds, distributes the assets, facilitates subscription or provides financial services tied to the offering may fall within the category.

A separate securities analysis is required when the virtual asset also qualifies as a security under Section 2 of Law No. 26,831. PSAV registration does not authorize an unapproved public offering of securities. General Resolution No. 1058/2025 prohibits PSAVs from offering or intermediating a public offering involving virtual assets that are securities unless the CNV has authorized the offering. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 37.)

Products That May Involve More Than One Activity

A single crypto product may involve several regulated activities at the same time. A centralized exchange may provide fiat-to-crypto exchange, crypto-to-crypto exchange, transfers and custody. A stablecoin payment product may perform exchange and transfer functions. A token-sale platform may provide Category 5 services while also receiving, holding or distributing virtual assets. General Resolution No. 1058/2025 therefore requires applicants to identify every category corresponding to their activities, rather than selecting one category that broadly describes the business. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6 and 8.)

Products described as crypto lending, staking, brokerage, DeFi access, treasury management or embedded crypto require functional analysis because those commercial labels do not appear as separate statutory categories. A lender using its own virtual assets may be outside the PSAV definition with respect to the lending itself, while still performing exchange, transfer or custody services within the same product. A staking interface may involve custody or transfer if the provider controls customer assets, while software that gives the user direct access to a protocol may present a different result. The classification must follow the specific flow of assets, authority over transactions and contractual role of each entity.

Foreign Companies Serving Argentine Users

A foreign company must register when it directly performs a covered PSAV activity through any one of the five territorial modalities established by Section 3 of General Resolution No. 1058/2025. The five connections operate independently. A foreign provider can therefore be brought within the Argentine regime through a local domain, a local ramp arrangement, clear targeting, locally directed advertising or the regulatory business-volume threshold. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 3.)

Once a foreign company is within the perimeter, it cannot satisfy the rule merely by filing its offshore incorporation documents with the CNV. It must conduct the regulated activity through an Argentine company involving a foreign shareholder registered under Section 123 of Law No. 19,550, or through a branch, establishment or other permanent representation registered under Section 118. The corporate route is examined separately in the section "Setting Up from Abroad." (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1.)

Use of an Argentine Domain

Use of any ".ar" domain to perform the relevant activities is an express territorial trigger. The provision does not require proof that the domain produced a minimum number of Argentine customers or transactions. A foreign provider conducting PSAV activities through an Argentine domain should therefore assume that the CNV will regard the activity as occurring in Argentina. The regulation refers to use of the domain to perform PSAV activities and does not expressly address the passive or defensive registration of an unused domain. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(1).)

Local Ramp Arrangements

A foreign company is also deemed to operate in Argentina when it has commercial agreements with third parties, subsidiaries or affiliates that allow it to receive funds locally from Argentine residents for covered activities, including arrangements commonly known as ramp services. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(2).)

This provision is broader than maintaining a bank account in the foreign company's own name. It can reach a structure in which an Argentine PSP, bank, collection provider, group company or commercial partner receives pesos from local users and connects those funds to the foreign company's crypto service. The contractual and technical flow should be reviewed together. Routing the fiat leg through a third party does not remove the territorial connection when the purpose of the arrangement is to fund the customer's activity with the foreign provider.

The local-ramp trigger will frequently coexist with other regulatory issues. A fiat payment partner may be subject to BCRA payment rules, while the foreign crypto provider may be subject to the CNV's PSAV regime. The fact that the local partner is regulated does not transfer the foreign provider's own PSAV responsibility to that partner.

Clear Targeting of Argentine Residents

A foreign company is within the perimeter when it has a clear direction toward residents of Argentina. General Resolution No. 1058/2025 does not define "clear targeting" or provide an exhaustive list of relevant factors. The analysis must therefore be based on the full customer-acquisition and product design. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(3).)

Evidence of targeting may include, as an interpretive matter, (a) Argentine-specific landing pages; (b) onboarding that expressly accepts Argentine identity or tax documents; (c) prices, limits or disclosures designed for Argentine residents; (d) local customer-support channels or hours; (e) commercial personnel assigned to Argentina; (f) partnerships intended to acquire Argentine users; (g) promotions tied to Argentine events or market conditions; and (h) product documentation stating that the service is available in Argentina. No single factor must necessarily control, and the analysis should distinguish genuine Argentine targeting from features used throughout a global product.

Spanish-language availability alone should not automatically be equated with targeting Argentina because the same language is used across multiple countries. The conclusion may change when Argentine terminology, local payment methods, local documentation, geolocation or country-specific campaigns are added. The relevant question is whether the foreign provider has taken affirmative steps to develop or serve the Argentine market.

Advertising Directed at Argentine Residents

Advertising clearly directed at Argentine residents is a separate registration trigger. It can include paid digital campaigns segmented for Argentina, local affiliate campaigns, promotions through Argentine media or influencers, and communications expressly inviting Argentine residents to open accounts or trade. The regulation focuses on the audience to which the advertising is directed, rather than the country from which the campaign is technically managed. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(4).)

A globally accessible website or untargeted global campaign is not expressly identified as advertising clearly directed at Argentina. This does not create a general exemption. The same company may still satisfy the clear-targeting test, use a local ramp, exceed the business-volume threshold or use a ".ar" domain.

Reverse Solicitation

General Resolution No. 1058/2025 states, within the advertising trigger, that the relevant situation does not include cases in which the customer contacts the foreign company. This is the regulation's express reference to reverse solicitation. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(4).)

The drafting does not establish reverse solicitation as a general safe harbor from the entire foreign-provider regime. The exception appears specifically within the rule concerning advertising directed at Argentine residents. A company contacted spontaneously by a customer may still be required to register if it uses a ".ar" domain, operates through a local ramp, clearly targets Argentine residents through other conduct or exceeds the 20 percent business-volume test.

Reverse solicitation should also be assessed from the events preceding the customer's contact. A customer's submission of an onboarding form is not meaningfully spontaneous when it follows an Argentina-specific advertisement, affiliate referral or local promotion. A company relying on reverse solicitation should be able to evidence the absence of prior directed solicitation and should avoid treating a clause in its terms of service as conclusive proof of how the relationship originated.

Recurring acceptance of Argentine users may also weaken the factual basis for treating the activity as isolated passive demand. The regulation does not establish a numerical limit on reverse-solicited customers. The exposure instead depends on whether the provider's broader conduct amounts to clear targeting or satisfies another territorial trigger.

The 20 Percent Business-Volume Test

A foreign provider is deemed to operate in Argentina when its Argentine business volume exceeds 20 percent of its total business volume. For this calculation, the regulation directs the provider to consider only the total business volume of the activity or activities requiring PSAV registration. Section 3 does not specify the measurement period, define whether business volume must be calculated by transaction value, revenue or another metric, or establish attribution rules for customers, corporate groups or intercompany activity. A provider applying the test should therefore adopt and document a reasonable methodology consistent with its operating model and apply it consistently. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3(5).)

The threshold is an independent trigger rather than a small-business exemption. A foreign provider may have to register well before Argentine activity reaches 20 percent if any of the other four connections is present.

Passive Access Versus Serving the Argentine Market

Mere technical accessibility of a global platform from an Argentine IP address is not expressly listed as a territorial trigger. That fact should not be converted into a categorical rule that passive availability can never create Argentine exposure. The applicable analysis asks whether the provider has engaged in one of the five forms of territorial connection established by the CNV. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3.)

At one end of the spectrum is a foreign platform that does not advertise in Argentina, has no local domain or ramp, has no Argentina-specific product features and receives an unsolicited inquiry from an Argentine resident. At the other end is a platform that accepts local documentation, integrates peso funding, markets through Argentine channels and repeatedly contracts with Argentine users. The first case may support a reverse-solicitation position in relation to advertising. The second presents multiple independent grounds for registration.

Between those cases, the company should document the customer journey and the entity flow before reaching a conclusion. The analysis should identify where each relevant act occurs, which entity performs it, how the customer found the service, how funds enter and leave the platform, who controls the assets, and whether any group company or third party supports the Argentine-facing activity.

Foreign Parent Companies and Local PSAV Subsidiaries

General Resolution No. 1058/2025 permits a foreign company, directly or through another company in its group, to participate in an Argentine company registered as a PSAV without requiring the foreign shareholder itself to register, provided that the foreign company has no direct contractual relationship with Argentine customers and is not independently caught by any of the five territorial connections. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 3, final paragraph.)

This provision allows a group to place the Argentine business in a local regulated subsidiary while retaining technology, intellectual property or group services abroad. It does not support a structure in which the local company is nominally registered but the offshore parent remains the true customer counterparty or directly performs the covered service. The contracts, product interfaces, asset flows, accounting records and operational responsibilities should identify the Argentine PSAV as the actual provider of the locally regulated activity.

Express Exclusions and the Individual Threshold

General Resolution No. 1058/2025 expressly excludes: (a) persons trading virtual assets solely for themselves; (b) persons receiving or delivering virtual assets as consideration for their own goods or services; (c) decentralized protocols where no identifiable service provider exists; and (d) providers acting exclusively as providers of self-custody wallets. These exclusions apply according to the actual activity. A business cannot rely on them for one function while ignoring a separate exchange, transfer, custody or offering service performed within the same product. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1.)

The regulation also contains a limited registration exception for individual PSAVs whose covered activities, aggregated during a calendar month, do not exceed 35,000 UVA, calculated using the UVA value on the final day of that month. The exception applies only to natural persons. It does not create a de minimis threshold for Argentine or foreign companies. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1.)

A decentralized label is likewise insufficient where an identifiable company or group continues to provide the service. The express exclusion requires both a decentralized protocol and the absence of an identifiable service provider. A front end, governance arrangement, fee mechanism, upgrade authority or operational entity may require closer analysis when it permits a person to control or provide the service despite the use of smart contracts.

The correct registration analysis should end with a clear mapping of: (a) each covered activity; (b) the legal entity performing it; (c) the contractual counterparty of the customer; (d) the territorial connection with Argentina; (e) any exclusion being relied upon; and (f) the PSAV category or categories required. That mapping should be completed before the group selects its Argentine corporate structure or begins preparing the CNV application.

Registry Categories

The CNV registry divides PSAV activities into five categories. An applicant must identify every category corresponding to the services it will actually perform, and a company whose product combines several regulated functions must register in each applicable category. The categories are cumulative classifications of activity, rather than alternative licenses from which the applicant may select the most convenient one. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6 and 8.)

Category 1: Exchange Between Virtual Assets and Fiat Currency

Category 1 covers the exchange of virtual assets for legal tender and legal tender for virtual assets. It generally includes platforms, brokers and OTC desks that allow customers to buy virtual assets with Argentine pesos or foreign fiat currency, or sell virtual assets in exchange for fiat currency. The classification can apply whether the provider matches customer orders, acts as the customer's counterparty or embeds the conversion within a broader service, provided that it performs the exchange as a business for or on behalf of the customer. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 1.)

A Category 1 analysis should identify which entity receives the fiat funds, which entity delivers the virtual assets and whether an Argentine bank, PSP, affiliate or collection provider participates in the flow. The use of a third-party payment rail does not change the category of the company that performs the exchange, although it may create additional regulatory issues for the payment leg.

Category 2: Exchange Between Virtual Assets

Category 2 covers the exchange of one or more forms of virtual assets. It includes crypto-to-crypto trading pairs and may apply to order-book exchanges, brokerage services, swap functions and other systems through which customers exchange one virtual asset for another. The category applies without any fiat-currency component. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 2.)

A platform offering both fiat-to-crypto and crypto-to-crypto trading will ordinarily require Categories 1 and 2. Internal settlement through book entries does not by itself remove the exchange from Category 2 where the provider operates the service and records the resulting change in customer entitlements.

Category 3: Transfer of Virtual Assets

Category 3 covers the transfer of virtual assets for or on behalf of another person. It may apply when a provider executes withdrawals, sends assets to an external wallet, moves virtual assets between customers, processes stablecoin remittances or otherwise causes assets or customer entitlements to move from one address or account to another. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 3.)

Category 3 frequently accompanies another classification. An exchange that permits customers to withdraw purchased assets may perform both exchange and transfer activities. A hosted wallet may combine transfer and custody. A cross-border product may combine exchange, transfer and custody within a single customer transaction.

The decisive issue is the provider's operational role. A company may perform a transfer service when it receives and authenticates the instruction, controls the sending wallet or internal ledger, and determines whether the transaction will be executed, even though the final on-chain settlement is processed by a decentralized network.

Category 4: Custody or Administration

Category 4 covers the custody or administration of virtual assets or instruments that permit control over them, provided that the service is not non-custodial. It applies to businesses that hold customer assets, control private keys, administer signing systems or otherwise possess the practical ability to authorize, prevent or redirect transactions involving customer assets. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 4.)

The category includes conventional hosted wallets and institutional custody services, but it can also reach multisignature and multiparty computation structures. The analysis should examine who controls each signing component, whether the customer can transact without the provider, whether the provider can freeze or reject a transaction, and who controls credential recovery.

A provider does not avoid Category 4 merely by delegating storage or key management to another custodian. General Resolution No. 1058/2025 expressly contemplates third-party custody and requires the registered PSAV to disclose the custody architecture, identify the third party, describe the relevant networks and wallets, publish proof of reserves, and maintain separation between its own assets and customer assets. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 15 and 16.)

By contrast, a provider acting exclusively as a self-custody wallet provider is outside the PSAV definition under Section 1 of General Resolution No. 1058/2025. The exclusion depends on the technical reality of the product. A contractual statement that the wallet is non-custodial will not resolve the classification if the provider retains sufficient control over keys, recovery procedures or transaction execution.

Category 5: Services Related to an Issuer's Offer or Sale

Category 5 covers participation in, and provision of, financial services related to an issuer's offer or sale of a virtual asset. The regulation specifically includes providers that make platforms or mobile applications available to issuers for an initial offering of virtual assets or operate a public means of raising funds to finance an issuer's projects. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8, Category 5.)

The mere issuance of a virtual asset does not place the issuer in Category 5. The category is directed at the service supplied around the offer or sale, such as operating the distribution platform, facilitating subscriptions, receiving purchaser funds or providing financial intermediation linked to the issuance. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 8.)

Category 5 does not replace the capital-markets analysis. Where the asset also qualifies as a security under Law No. 26,831, the offer, placement and intermediation may be subject to separate CNV rules. PSAV registration does not authorize the public offering of a security that otherwise requires CNV approval.

Registration in Multiple Categories

The applicant must map the complete customer and asset flow and register in every category reflected in that flow. A centralized exchange offering peso deposits, crypto trading, hosted balances and external withdrawals may require Categories 1, 2, 3 and 4. A token-distribution platform that receives purchaser assets, holds them temporarily and distributes newly issued tokens may require Category 5 together with Categories 3 or 4, depending on the operational model.

Registration in several categories does not require the applicant to aggregate the minimum net worth established for each one. General Resolution No. 1058/2025 provides that a PSAV registered in two or more categories must satisfy the minimum net worth applicable to the most demanding category. The precise financial requirements and the reduced thresholds available to certain lower-volume providers are addressed in the section "Substantive Requirements." (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 9.)

The selected categories also determine which operational materials must be prepared. Procedure manuals must address the purchase, sale and exchange orders and the technical and operational procedures for custody, administration and transfers, as applicable to the categories requested. Category 4 applicants face additional custody-specific requirements concerning architecture, proof of reserves, asset segregation and key-security arrangements. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 11 and 15 to 19.)

Natural persons may register only under Categories 1 and 2. Categories 3, 4 and 5 must therefore be conducted through an eligible legal entity. For foreign groups, the practical applicant will ordinarily be an Argentine SA or SRL involving a foreign shareholder registered under Section 123 of Law No. 19,550, or a branch or permanent representation registered under Section 118. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1, 6 and 8.)

Category selection should be completed before preparing the application, corporate capital structure and operating manuals. An incomplete classification can cause the applicant to understate its financial requirement, omit required technical documentation or present a business model that is inconsistent with its customer contracts and systems.

Setting Up from Abroad

A foreign company that falls within the Argentine PSAV perimeter must choose one of two local structures before applying to the CNV: it may establish an Argentine SA or SRL involving a foreign shareholder registered under Section 123 of the General Companies Law, or register the foreign company itself under Section 118 as a branch, establishment or other permanent representation. The offshore entity cannot obtain PSAV registration in its original foreign form without using one of those routes. The choice determines who becomes the regulated service provider, who contracts with Argentine customers, where regulatory capital is maintained and which entity bears the liabilities arising from the local business. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 6(b); Law No. 19,550, Sections 118 and 123.)

The Two Permitted Corporate Routes

Under the subsidiary route, the applicant is a company incorporated in Argentina as an SA or SRL. The foreign company, or another company belonging to the same corporate group, registers under Section 123 of Law No. 19,550 and participates as a shareholder or partner of the Argentine applicant. Under the branch route, the foreign company registers under Section 118 and becomes the PSAV applicant through its Argentine branch or permanent representation. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 6(b).)

These routes are legally distinct. A Section 123 registration qualifies the foreign company to constitute or participate in an Argentine company, but the regulated operator is the resulting local company. A Section 118 registration allows the foreign company itself to carry on habitual business in Argentina through a registered local presence. The contracts, website, customer onboarding, accounting records and flow of assets should reflect the route actually selected. (Law No. 19,550, Sections 118 and 123; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b).)

The Argentine Subsidiary Route

A foreign group using the subsidiary route must first register the relevant foreign shareholder under Section 123 of Law No. 19,550. Section 123 requires a foreign company wishing to constitute an Argentine company to prove that it was validly formed under the law of its home jurisdiction and register its constitutional documents, amendments, enabling documentation and local representative with the competent Public Registry.

For a company registered in the City of Buenos Aires, the current IGJ rules require, among other documents, (a) a certificate of good standing or registration issued no more than six months before filing; (b) the foreign company's constitutional instrument and amendments, or an eligible consolidated version; (c) a resolution of the competent corporate body approving the Argentine registration and appointing a legal representative with specified powers; (d) the representative's acceptance and special domicile; and (e) politically exposed person and beneficial-ownership declarations. The competent registry in another Argentine province may apply different procedural rules. (IGJ General Resolution No. 15/2024, as amended by IGJ General Resolution No. 4/2026, Section 164(1).)

Foreign documents submitted in Buenos Aires must comply with the formalities of their jurisdiction of origin, be authenticated and apostilled or legalized as applicable, and be accompanied by a Spanish translation prepared by a registered public translator when the original is in another language. Planning the document package at the outset is material because defects in certification, authority, apostille or translation can delay both the Section 123 registration and the incorporation of the PSAV applicant. (IGJ General Resolution No. 15/2024, Section 6(6) and Section 203.)

The foreign shareholder registration and the incorporation of the local company may be filed together before the IGJ when the foreign company's direct participation appears in the local incorporation instrument. In that case, registration of the Argentine company remains conditional on full compliance with the requirements applicable to the foreign shareholder. This concurrent procedure can reduce sequencing delays, although it does not eliminate the need to prepare the complete foreign-document package. (IGJ General Resolution No. 15/2024, as amended by IGJ General Resolution No. 4/2026, Section 164.)

Once incorporated, the Argentine SA or SRL becomes a separate legal person and submits the PSAV application in its own name. The application must identify its shareholders, governing and supervisory bodies, registered and operational addresses, legal representative, tax identification number, applicable PSAV categories and the persons holding the regulatory functions required by General Resolution No. 1058/2025. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b).)

Choosing Between an SA and an SRL

The CNV permits an Argentine PSAV applicant to use an SA or an SRL. A simplified joint-stock company, or SAS, is not one of the corporate forms admitted by Section 6 of General Resolution No. 1058/2025. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b).)

An SA has capital represented by shares and is administered by a board of one or more directors. An absolute majority of the directors must have their actual domicile in Argentina, and every director must establish a special domicile in the country for notices connected with the position. An SA can also be formed as a wholly owned company, in which case it is organized as a sociedad anónima unipersonal, or SAU. (Law No. 19,550, Sections 1, 163, 255 and 256.)

An SRL has capital divided into quotas, may have no more than fifty partners and is administered by one or more managers. Its constitutional agreement can allocate management powers among the managers or provide for joint or collegiate action. Because Argentine law permits a single-member company only in the form of an SA, an SRL requires at least two genuine partners. Arrangements involving an apparent or nominee partner are expressly prohibited. (Law No. 19,550, Sections 1, 34, 146 and 157.)

In practice, an SRL is often suitable for a closely held subsidiary with two genuine group shareholders and no immediate need for a share-based investment structure. An SA is generally more suitable where the group wants a wholly owned subsidiary, expects external investment, or prefers governance through a board and transferable shares. The selection should be made before the foreign shareholder adopts its corporate resolution because that resolution should identify the contemplated investment and authorize the persons who will execute the Argentine formation documents.

The choice of SA or SRL does not alter the substantive PSAV requirements. Either entity must satisfy the applicable minimum net worth, governance, systems, custody, cybersecurity, customer-protection and AML standards. The CNV application should describe the local entity as the actual operator rather than as a nominal registration vehicle for services legally supplied by the foreign parent. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6 and 9 to 40.)

The Branch Route Under Section 118

A foreign company may instead register a branch, establishment or other permanent representation under Section 118 of Law No. 19,550. To carry on habitual activity through that route, the foreign company must prove its existence under the law of its jurisdiction of incorporation, establish a domicile in Argentina, justify the decision to create the local representation and appoint the person who will be responsible for it. If the structure is a branch, the foreign company must also determine the capital assigned to it when required by a special law. (Law No. 19,550, Section 118.)

A branch is not a separate Argentine company. The foreign company remains the legal service provider and bears the obligations generated by the Argentine operation. The branch must maintain separate accounting records in Argentina, and its local representative has the responsibilities that the General Companies Law assigns to corporate administrators. (Law No. 19,550, Sections 120 and 121.)

For registration in Buenos Aires, the branch must submit the foreign-company documents and declarations required for a Section 123 registration, together with a corporate resolution specifying (a) the decision to operate in Argentina; (b) the form of permanent representation selected; (c) the local representative; (d) the registered office in Buenos Aires, or authority for the representative to establish it; (e) the financial year-end; and (f) any capital assigned to the branch. Certain foreign corporate forms must also publish the notice required by Section 118. (IGJ General Resolution No. 15/2024, as amended by IGJ General Resolution No. 4/2026, Section 164(2).)

Registration under Section 118 is sufficient for the foreign company's habitual activity and, under the current IGJ rules, dispenses with a separate Section 123 registration. The foreign company would still need Section 123 treatment if it later cancelled the branch registration but wished to retain an investment in an Argentine company. (IGJ General Resolution No. 15/2024, Section 166, as amended by IGJ General Resolution No. 4/2026.)

For the PSAV application, the foreign company's corporate purpose and the activities assigned to the local representative must include, expressly or implicitly, the PSAV activities for which registration is sought. The branch must identify its local representatives and provide their corporate appointment documents, criminal-record certificates and AML declarations. Its representatives must also declare that the branch has its own administrative organization adequate to provide PSAV services. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(3), (4), (12), (13), (14) and (19).)

Which Route Is Usually Preferable?

A subsidiary generally provides clearer separation between the Argentine operation and the foreign parent. The Argentine company can enter into local customer, employment, banking, technology and vendor contracts in its own name, while the foreign shareholder's exposure is ordinarily limited by the selected corporate form and the general rules on shareholder liability. The cost is an additional corporate layer, local books, local governance and the need to register the foreign shareholder under Section 123.

A branch preserves the foreign company as the customer-facing entity and may be appropriate when the group requires contractual continuity with the parent. It also places the Argentine PSAV activity directly on the foreign company's balance sheet. The corresponding disadvantage is that the branch provides no separate corporate liability shield, requires separate Argentine accounting and exposes the foreign company itself to the local regulatory, contractual and enforcement framework. (Law No. 19,550, Sections 118 to 121.)

Neither route should be selected solely on the assumption that it will be faster. A subsidiary requires the Section 123 process and local incorporation, although both filings may proceed together in Buenos Aires. A branch avoids the creation of a separate company but requires registration of the foreign operator, appointment of a local representative and preparation of a local accounting and administrative structure. The ownership chain, home jurisdiction, availability of corporate documents and intended allocation of liability often have a greater effect on timing than the nominal choice between Sections 118 and 123.

Corporate Purpose and Operating Model

The constitutional documents must support the activities submitted to the CNV. For a subsidiary, the local company's corporate purpose must include, expressly or implicitly, the relevant PSAV services. For a branch, the purpose of the foreign company and the activities assigned to the Argentine representative must support those services. A company applying in Categories 1, 2, 3 and 4 should avoid presenting a corporate purpose or parent authorization that appears limited to software development or general consulting. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(3).)

The local structure should also match the contractual and technical flow. The intended PSAV applicant should be identified as the provider in the terms of service, customer disclosures and complaints channel. It should be able to account for customer transactions, exercise the operational responsibilities described in the application and control the third-party agreements on which the service depends. A structure in which the Argentine entity appears in the registry while the offshore company continues to contract directly with local customers creates a material inconsistency with the regulatory filing.

Ownership and Beneficial-Ownership Documentation

The ownership chain should be mapped before foreign documents are issued. The Argentine corporate registry requires disclosure of the natural persons who qualify as ultimate beneficial owners and supporting documents tracing the chain of ownership or control. The CNV application separately requires current shareholder information, and the applicant's ownership and management will also be examined under the integrity and solvency framework discussed later in this guide. (IGJ General Resolution No. 15/2024, Section 421; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(11).)

The same ownership chart should be used consistently for the corporate registration, CNV application, UIF registration, bank onboarding and internal AML files. Differences in names, ownership percentages, intermediate holding companies or control rights commonly generate additional requests for documentation.

CUIT, Local Addresses and Regulatory Contacts

The PSAV applicant must obtain an Argentine tax identification number, or CUIT. ARCA uses the CUIT to identify companies and other registered taxpayers, and General Resolution No. 1058/2025 requires the applicant to include its CUIT in the CNV filing. The entity must also establish the necessary authority for a legal representative or appointed administrator to act through ARCA's electronic systems.

The CNV application must identify the registered office, branches, operational addresses and a legal address accessible to customers. It must also provide an Argentine telephone number, an electronic address for CNV notices, a customer-complaints email address and an institutional website using a ".ar" domain. These requirements should be addressed during the corporate setup rather than after the regulatory file has been prepared. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(5) to (9).)

A branch must have a locally appointed representative under Section 118. An SA must structure its board so that an absolute majority of its directors have their actual domicile in Argentina. The PSAV must also identify a Regulatory Compliance and Internal Control Officer and a Customer Relations Officer, whose substantive functions are discussed in later sections. (Law No. 19,550, Sections 118 and 256; CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(15) and (16).)

Banking and Fiat Infrastructure

General Resolution No. 1058/2025 does not expressly list an Argentine bank account as a standalone condition for submitting the PSAV application. A local account may nevertheless be operationally necessary where the product receives or delivers fiat currency, pays local expenses, funds the applicant's operations or integrates with an Argentine bank or PSP. The account-opening process should therefore begin early and proceed in parallel with the corporate and regulatory work.

Bank onboarding is a separate decision made by the financial institution under its own customer-identification and risk policies. The bank will commonly request the foreign corporate documents, beneficial-ownership chart, source-of-funds evidence, business plan, regulatory analysis and an explanation of the fiat and virtual-asset flows. PSAV registration should not be presented as a guarantee that a particular institution will open or maintain an account.

A Practical Chronology

For most foreign groups, the work should proceed in the following order: (a) determine whether the intended services require PSAV registration and select the applicable categories; (b) identify the legal entity that will perform each regulated activity; (c) choose between a subsidiary and a branch; (d) prepare the ownership chart and foreign corporate resolutions; (e) obtain, authenticate and translate the foreign documents; (f) complete the Section 123 or Section 118 registration and, where applicable, incorporate the Argentine SA or SRL; (g) obtain the CUIT, establish local addresses and appoint the required representatives and officers; (h) begin bank and payment-partner onboarding; (i) capitalize the applicant and prepare its operational, technology, custody, cybersecurity and AML framework; and (j) submit the PSAV application through TAD and the related information through AIF.

The corporate work and the regulatory work should overlap. Waiting for the company to be fully registered before designing the PSAV operating model usually extends the project, while preparing the application without first fixing the applicant, ownership chain and local governance produces documents that later need to be revised. The efficient sequence is to decide the structure early and develop the corporate, financial, technology and compliance workstreams against the same approved operating model.

Substantive Requirements

PSAV registration requires the applicant to demonstrate that it has sufficient financial resources, an adequate local organization, documented operating procedures, secure information systems and effective controls over customer assets and regulatory compliance. These requirements apply before registration and continue throughout the PSAV's operation. The CNV can request supplementary evidence beyond the documents expressly listed in General Resolution No. 1058/2025, and the applicant must certify that it complies with all requirements applicable to the categories for which registration is requested. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6, 9 to 22 and 24 to 30.)

Minimum Net Worth

The minimum net worth requirement depends on the PSAV category. Categories 1, 2 and 4 require net worth equivalent to USD 150,000; Category 3 requires USD 75,000; and Category 5 requires USD 35,000. A provider registered in more than one category does not add the amounts together: it must satisfy the requirement corresponding to the most demanding applicable category. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 9.)

A reduced requirement applies to certain lower-volume providers. For Categories 1, 2 and 3, the minimum net worth is reduced by 50 percent when the provider has processed less than USD 2.5 million during the preceding twelve months. For Category 4, the same reduction applies when the value of assets held in custody during the preceding twelve months is below USD 2.5 million. Section 9 does not extend this reduced requirement to Category 5. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 9.)

The reduced requirement should not be treated as a permanent classification. A PSAV that grows above the relevant threshold must maintain the full amount applicable to its category. Section 9 does not expressly address how a newly formed applicant with no twelve-month operating history must establish its eligibility for the reduction. A new applicant relying on the reduced requirement should disclose its lack of historical activity and clearly explain the period, entities and projected or actual activity used as the basis for its calculation. The CNV may request additional supporting information under Section 6. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6 and 9.)

Customer virtual assets cannot be counted toward the PSAV's net worth. General Resolution No. 1058/2025 requires customer assets to be recorded as memorandum accounts rather than assets of the provider, and expressly excludes them from the net worth calculation. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 16.)

Evidence of Net Worth

A legal-entity applicant must submit its latest annual financial statements, or financial statements covering the period since incorporation if the company is newer, as filed with the competent corporate authority and audited by an independent public accountant. If those financial statements are more than eight months old when the complete application is filed, the applicant must also provide a certification issued by an independent public accountant whose signature has been authenticated by the relevant professional council. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(18).)

Net worth must be measured as of a date no more than two months before the filing and stated in US-dollar equivalent using the exchange rate established under BCRA Communication "A" 3500, as amended. This is a regulatory measurement rule. It does not require the applicant's capital or assets to be legally denominated or held in US dollars. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(18).)

The applicant must continue meeting the requirement after registration. If its annual financial statements show net worth below the applicable amount, the PSAV must report the deficiency to the CNV as a material event and, within ten business days, submit details of the measures it will take to restore compliance. General Resolution No. 1058/2025 does not convert that notification period into a general ten-day cure period. The filing must explain the intended recapitalization or other corrective measures, while the underlying duty to maintain the minimum remains in force. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 10.)

Local Organization and Governance

The applicant must have its own administrative organization adequate to provide the proposed PSAV services. An Argentine company must record this conclusion in a sworn statement adopted by its governing body. A foreign company operating through a Section 118 branch must obtain the equivalent declaration from its local representatives. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(19).)

This requirement makes the local applicant more than a formal holder of the registration. The entity presented to the CNV must be capable of discharging the responsibilities allocated to it in the application, including control of the customer relationship, oversight of delegated functions, access to records, regulatory reporting and implementation of corrective measures. Group technology and operational resources may support the Argentine PSAV, but the applicant should be able to explain how its governing body and local officers exercise effective control over those resources.

General Resolution No. 1058/2025 requires the applicant to identify its shareholders, directors, managers, supervisory body members where applicable, local branch representatives and certain senior managers. The regulation also requires updated criminal-record certificates and AML declarations from the persons expressly covered by Section 6. Changes to the governing and supervisory bodies must be reported within ten business days. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(11) to (14).)

Certain persons are barred from serving as directors, supervisory body members, local representatives or Regulatory Compliance and Internal Control Officers. The incompatibilities include persons legally unable to conduct business, persons convicted of specified insolvency, profit-motivated or public-trust offenses during the applicable period, persons convicted of money laundering or terrorist financing, persons listed by the United Nations Security Council, certain former bankrupts or reorganization debtors and persons disqualified under Section 132(c) of Law No. 26,831. A person who becomes subject to an incompatibility after registration must immediately notify the CNV and cease performing the function. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 7.)

Regulatory Compliance and Internal Control

Every PSAV must appoint a Regulatory Compliance and Internal Control Officer. The governing body, or the local representatives of a branch, must evaluate the appointee's personal and professional background. The officer may be a member of the governing body or a local branch representative, but must perform the control functions assigned by the regulation. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 21.)

The officer must assess the adequacy and effectiveness of the PSAV's procedures, monitor internal controls, recommend corrective action, supervise compliance with the Code of Conduct and verify that customer complaints are handled through the required process. The scope of the review must take into account the specific activity, the provider's governance, the available control documentation and the complexity of its operations. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 21(a) to (d).)

Within seventy calendar days after the end of each calendar year, the officer must submit through AIF a report setting out the results of the examinations performed during the year. When the officer is not a member of the governing body, the officer reports directly to that body or to the branch's local representatives. The PSAV must provide the officer with the resources and access to information required to perform the role. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 21(e).)

This officer is distinct from the AML Compliance Officer required under the UIF framework. The CNV officer supervises compliance with the PSAV rules and the CNV's regulations, while the UIF officer directs the AML, counter-terrorist-financing and counter-proliferation-financing program. The same organizational chart may contain both roles, but the company should avoid merging their mandates in the regulatory documents without first confirming that the proposed arrangement satisfies both regimes.

Operating Manuals and Transaction Records

The PSAV must maintain procedure manuals covering the functions applicable to its categories. These include the processing of purchase, sale and exchange orders and the technical and operational procedures used for custody, administration and transfers. The manuals must remain available to the CNV. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 11.)

The transaction-recording procedures must preserve, at a minimum, the date and precise time at which offers and transactions are entered, the quantity offered, the type of virtual asset, the internal transaction identifier or blockchain hash and the identity of the customer. A platform or wallet must also maintain an accurate, auditable and verifiable electronic ledger recording each transaction and must have systems capable of monitoring operations, detecting relevant failures and recovering damaged or deleted information. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 11 and 27.)

The manuals should correspond to the actual system configuration and customer terms. A regulatory file that describes immediate on-chain settlement, for example, should not conflict with a product that settles customer entitlements through an internal ledger and batches blockchain transactions. The CNV will be able to compare the procedure manuals, systems report, custody diagram, contracts and periodic information.

Information Systems

A PSAV must keep a detailed description of the information systems used in its regulated activities. The systems must support customer protection, fairness, efficiency, transparency, non-fragmentation and reduction of systemic risk. The applicant must submit through AIF a report from an IT expert addressing the immutability of recorded information, system security, backup and contingency procedures and the other relevant system functions. The report is not public. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 12.)

The regulation does not require the IT expert to be Argentine for the annual systems audit, and expressly permits that report to be signed by a domestic or foreign expert. The PSAV should nevertheless confirm that the expert's report addresses each regulatory requirement and is capable of being presented in the form required by AIF. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 20.)

Cybersecurity

The cybersecurity framework must follow a risk-based approach and cover governance, identification, protection, detection, response and recovery. The PSAV must conduct periodic internal cybersecurity assessments and audits, identify weaknesses and prioritize the critical processes that require protection. Those processes include order and transfer systems, infrastructure risk-management systems, custody systems for virtual assets or fiat currency, information-distribution systems and systems containing nonpublic customer information. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 13(a) and (b).)

Required protective measures include safeguards for customer information, controls over interconnections with other platforms and wallets, detection of anomalous employee behavior, personnel access controls and cybersecurity training for employees with access to restricted systems. The systems must also be capable of detecting potential incidents or security breaches, conducting continuous or low-latency monitoring and maintaining layered access controls. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 13(c) and (d).)

The response and recovery arrangements must allow the PSAV to continue essential functions, restore critical systems after a cyberattack and reduce the effects of an interruption. These requirements should be translated into an incident-response plan, escalation rules, recovery responsibilities, backup procedures and tested business-continuity measures rather than addressed through a general information-security statement. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 13(e).)

Information-Security Policies

The PSAV must adopt Information Security Policies approved by its governing body or, in the case of a Section 118 branch, by its local representatives. Those policies must describe the technical and operational systems used for private-key custody, categorize the wallets used for different operational purposes, identify the type of wallet used in each category and specify the transaction-security protocols applicable to each wallet type. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 14.)

The policies must also govern the granting and revocation of access to private keys and establish the technical and operational standards for the security and resilience of systems used in virtual-asset transactions and custody. The documents submitted to the CNV must avoid disclosing information that would itself compromise asset security or directly associate critical roles, infrastructure components or processes with identifiable persons. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 14 and 22.)

Custody Architecture and Proof of Reserves

A Category 4 PSAV must provide through AIF a description and diagram of its custody architecture. The filing must identify the structure and purpose of proprietary and customer wallets, whether custody is performed directly or through a third party, the blockchains or distributed-ledger technologies used, the provider's operational wallet addresses, whether wallets are cold, warm or hot, whether they use software or hardware and whether the key arrangement uses multisignature, MPC or another method. The information must be kept current and is not public. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 15.)

Category 4 providers must also publish proof of reserves on their website or application. Section 15 establishes the publication obligation but does not prescribe a calculation methodology, publication frequency, external-assurance standard or required form of verification. The PSAV must therefore design a method capable of supporting the accuracy and intelligibility of the published information while remaining consistent with its custody architecture, internal ledger and asset-segregation controls. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 15.)

Segregation of Customer Assets

A Category 4 PSAV must maintain clear separation between its own virtual assets and customer virtual assets. The separation must be identifiable and current in the internal ledger, in operational accounts maintained with another PSAV and in third-party wallets or accounts used under the custody arrangement. The customer contract must clearly state the operating structure and legal treatment of the custody or deposit. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 16.)

The provider may maintain a clearly identified margin of its own virtual assets in a wallet holding customer assets to cover immediate liquidity needs arising from customer transactions. This operational allowance does not permit commingling in the accounting records or the treatment of customer assets as property of the PSAV. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 16.)

When custody is delegated to a third party, the PSAV must use a wallet maintained with that third party exclusively for customer operations and separate from wallets holding the PSAV's proprietary portfolio. Delegation does not transfer regulatory responsibility: the PSAV remains fully responsible for the third party's performance and for compliance with the applicable CNV requirements. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 16 and 35.)

Prudential Controls Over Private Keys

Category 4 providers must use technological mechanisms designed to mitigate theft or loss of private keys. The architecture must incorporate different levels of verification and human participation based on predefined transaction thresholds, together with one or more safeguards such as cold storage, geographic separation of keys or key shares, multisignature authorization with defined roles, whitelisting of withdrawal addresses or another arrangement offering equivalent protection. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 17.)

The regulation does not impose a single custody architecture. It requires the applicant to justify how its selected design provides equivalent security, controls unauthorized employee and external access, and aligns transaction approval with the risk and value of the transaction. An MPC structure may satisfy the rule, for example, but the filing must explain key-share control, recovery, role allocation, transaction thresholds and the conditions under which a transaction can be approved.

Segregation of Fiat Funds

A PSAV handling fiat currency must maintain clear separation between customer-related funds and funds used for its own operations. That separation must be clearly, individually and currently reflected in the provider's internal records. Customer funds may be deposited in a bank account held in the PSAV's name with an Argentine financial institution, in an account abroad with an institution meeting equivalent Basel III security standards, or handled through a payment service provider registered with the BCRA, provided the BCRA's rules permit the arrangement. In each case, the funds must be maintained for the customers' benefit. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 18.)

A PSAV that holds or administers customer virtual assets or fiat funds may not use them for its own account. It must manage the assets according to the customers' express instructions and transfer them to the addresses designated by the customers. This restriction materially limits rehypothecation, proprietary trading and treasury use of customer assets unless another legally valid product structure places the assets outside the custody relationship described by Sections 16 to 19. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 19.)

Annual Systems Audit

The information systems used in the PSAV's activities must undergo an annual audit covering, at a minimum, operation, security, service continuity, immutability of records, backup procedures, proof of reserves and the other system requirements applicable to the relevant category. The audit report may be signed by an Argentine or foreign IT expert. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 20.)

The governing body must record the audit conclusions and recommendations in its minutes, even when the audit identifies no deficiencies. It must also record its own analysis and any measures adopted to improve the system or correct deficiencies. A Section 118 branch must make the corresponding record in a special book maintained by its local representatives. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 20.)

Conduct, Customer Protection and Risk Management

The PSAV must act honestly, impartially, professionally, diligently and loyally in the customer's best interest. It must provide understandable information, communicate in a clear and non-misleading manner, identify and mitigate conflicts, avoid placing proprietary orders ahead of pending customer orders of the same nature, disclose fees and risks, protect assets under custody and maintain effective governance and secure systems. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 24.)

The provider must publish a Code of Conduct addressing employee conduct, customer rights, conflicts of interest, fair treatment and AML policies. Trading platforms must adopt measures to prevent manipulation, misleading signals, artificial price movements, disruption of platform operation and misuse of privileged information. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 25 and 26.)

The PSAV must maintain and update risk-management policies that identify, assess and mitigate risks according to applicable regulatory standards and international practices. Those policies must address measures intended to prevent regulatory breaches and the steps to be taken once a breach occurs, including the parameters guiding the response and the persons responsible for implementing it. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 28.)

A Customer Relations Officer must be appointed to ensure that customer questions and complaints are addressed. The PSAV must maintain a direct and clearly accessible channel to that officer and procedures that permit prompt, impartial and consistent handling of claims. A complaints email address must be published and reported through AIF. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 29 and 30.)

Integrity and Solvency Review Under General Resolution No. 1139/2026

General Resolution No. 1139/2026 makes registration dependent on a substantive CNV assessment of the applicant and the relevant individuals behind it. The general regime refers to idoneity, integrity and solvency, but the resolution expressly provides that the idoneity requirement in Section IV, Section 11(1), does not apply to PSAVs "at this stage." As the current text stands, a PSAV applicant is therefore subject to the integrity and solvency review, while the specific idoneity limb is temporarily excluded. (CNV General Resolution No. 1139/2026, Article 4; CNV Rules, Title XI, Section IV, Sections 6 to 11.)

For a legal entity, the CNV assesses the directors, administrators and all persons performing management functions. Beneficial owners are assessed for integrity, but not under the solvency limb. The beneficial-owner threshold is 10 percent of capital or voting rights, together with any natural person who otherwise exercises ultimate direct or indirect control. Subsequent appointments and beneficial-owner changes must also be notified for review. (CNV Rules, Title XI, Section IV, Sections 9 and 10, as amended by CNV General Resolution No. 1139/2026.)

The integrity assessment considers whether the relevant person has been convicted or prosecuted for an intentional offense, particularly money laundering, terrorist financing, proliferation financing or an economic crime. The required evidence includes an AML declaration, a current criminal-record certificate and a politically exposed person declaration in the form required by the UIF. The CNV also checks United Nations Security Council lists and the Argentine Public Registry of Persons and Entities Linked to Acts of Terrorism and Terrorist Financing, known as RePET. (CNV Rules, Title XI, Section IV, Section 11(2), as amended by CNV General Resolution No. 1139/2026.)

The solvency assessment examines negative commercial history as an indicator of prudent financial administration. Relevant matters include unjustified payment defaults, judgments in economic or debt-collection proceedings, bankruptcy and repeated seizures or attachments. The CNV checks public and private databases for persons holding an Argentine CUIL, CUIT or CDI; otherwise, the applicant must provide a current commercial-background report. (CNV Rules, Title XI, Section IV, Section 11(3), as amended by CNV General Resolution No. 1139/2026.)

These conditions are continuing requirements. A registered PSAV must preserve the integrity and solvency conditions on which the registration was granted, and failure to do so results in expiration of the CNV registration under Section 12. The CNV will give particular weight to communications received from the UIF concerning sanctions for breaches of AML, counter-terrorist-financing or counter-proliferation-financing duties. (CNV Rules, Title XI, Section IV, Section 12, as amended by CNV General Resolution No. 1139/2026.)

For a foreign group, this review should begin before the Argentine entity is incorporated or its board is appointed. Criminal records, PEP status, commercial history and beneficial ownership may need to be documented across several jurisdictions. Replacing a director or restructuring the ownership chain after the filing can require renewed disclosures and a new CNV assessment.

AML Obligations

Every registered PSAV is an obligated entity under Argentina's anti-money laundering regime and must implement a risk-based system for the prevention of money laundering, terrorist financing and proliferation financing. The principal PSAV-specific rule is UIF Resolution No. 49/2024, which governs risk assessment, customer due diligence, transaction monitoring, suspicious transaction reporting, recordkeeping, internal controls and the travel rule. CNV General Resolution No. 1139/2026 adds a parallel obligation to submit specified AML information and documents to the CNV through its AIF platform. (Law No. 25,246, Section 20(13), as amended by Law No. 27,739; UIF Resolution No. 49/2024, Section 1; CNV Rules, Title XI, Sections I and II, as replaced by CNV General Resolution No. 1139/2026.)

PSAVs as Obligated Entities

Law No. 27,739 added PSAVs to the list of entities required to report to the UIF under Section 20 of Law No. 25,246. Registration with the CNV and compliance with the UIF regime are therefore separate obligations arising from the same regulated activity. CNV registration authorizes the provider to operate within the PSAV perimeter, while the UIF framework governs how the provider must identify and mitigate financial-crime risk. (Law No. 25,246, Sections 20(13) and 21; Law No. 27,739; UIF Resolution No. 49/2024, Section 1.)

After obtaining CNV registration, the PSAV must register as an obligated entity through the UIF's SRO+ system and register its principal and alternate Compliance Officers. Under UIF Resolution No. 50/2011, as amended by UIF Resolution No. 37/2026, the PSAV must upload the required supporting documentation through SRO+ at the time of registration. The filing remains subject to UIF review and validation, and any observed or missing documentation must be corrected within fifteen administrative business days. (UIF Resolution No. 50/2011, Section 3 bis, as replaced by UIF Resolution No. 37/2026, Section 1.)

The Risk-Based AML System

The PSAV must implement a system containing the policies, procedures and controls required to identify, evaluate, monitor, manage and mitigate its exposure to money laundering, terrorist financing and proliferation financing. The system must reflect the national risk assessments, information issued by competent authorities and the specific risks identified through the PSAV's own business. (UIF Resolution No. 49/2024, Sections 3 and 4.)

At a minimum, the assessment must address risks associated with: (a) customers; (b) products and services; (c) distribution channels; and (d) geographic areas. For a crypto business, that analysis should distinguish between custody and non-custody products, fiat and crypto funding methods, supported assets, customer types, P2P activity, cross-border transfers, exposure to privacy-enhancing services and the jurisdictions from which assets originate or to which they are sent. The provider must conduct a separate risk analysis before launching a new product, practice or technology that materially changes its operations. (UIF Resolution No. 49/2024, Section 4.)

A foreign group should not simply translate its global AML policy and treat it as the Argentine system. The local documentation must address the services offered by the Argentine PSAV, the customers it accepts, the transaction flows under its control and the risks identified by the Argentine regulatory framework.

Risk Self-Assessment and Risk Tolerance

The PSAV must prepare a technical self-assessment report identifying and evaluating its inherent risks and the effectiveness of the measures adopted to mitigate them. The report must be self-contained, supported by a documented methodology and updated annually, or earlier if the provider's risk level changes. A provider beginning operations must complete the assessment before launch using its projected business plan and the circumstances expected to affect its risk. (UIF Resolution No. 49/2024, Section 5.)

The governing body must also approve a reasoned statement of risk tolerance identifying the degree and type of AML risk the PSAV is prepared and able to assume. The statement must precede the actual exposure and be consistent with the provider's resources, controls, strategy and business plan. The self-assessment, methodology and risk-tolerance statement must be sent to the UIF and the CNV before April 30 of each applicable calendar year. (UIF Resolution No. 49/2024, Sections 5 and 6.)

Filing the assessment does not constitute regulatory approval of its methodology or conclusions. The UIF may review its logic, consistency and reasonableness and require amendments. The document should therefore explain the basis for each risk rating, the available data, the controls being relied upon and any residual risk accepted by the board. (UIF Resolution No. 49/2024, Section 5.)

AML Manual and Board Responsibility

The PSAV must maintain an AML manual containing the policies, procedures and controls required by UIF Resolution No. 49/2024. The methodology used to determine monitoring rules and parameters must be referenced in the manual, although confidential technical details may be maintained in separate internal documents available to the UIF and CNV. The manual must be reviewed at least annually, kept current and made available to directors, managers, employees and relevant contractors. (UIF Resolution No. 49/2024, Sections 8 and 9.)

The governing body remains responsible for the AML system. Its functions include approving the risk assessment, methodology, risk tolerance, manual, Code of Conduct, monitoring policies, annual compliance plan, training plan and remediation measures arising from internal or external reviews. It must allocate resources appropriate to the size and complexity of the PSAV and continuously review whether the system functions effectively. (UIF Resolution No. 49/2024, Section 10.)

This responsibility cannot be delegated entirely to the Compliance Officer or to a foreign group compliance team. The local governing body must understand the principal risks and be able to evidence its approval, oversight and response through minutes and other corporate records.

Compliance Officer and AML Committee

The PSAV must appoint a principal Compliance Officer and an alternate, both of whom must be registered with the UIF and have appropriate AML training or experience. They must establish a domicile in Argentina for UIF notices. The PSAV must ensure that a qualified officer is in office at all times, and the principal officer must exercise the role with autonomy, independence and unrestricted access to the information required for the function. (UIF Resolution No. 49/2024, Section 11.)

The Compliance Officer is responsible for implementing the AML system, preparing the risk assessment and manual, overseeing customer due diligence, defining alerts, supervising transaction monitoring, analyzing unusual activity, deciding whether an operation is suspicious and submitting the required reports. The officer must also approve the commencement or continuation of relationships with high-risk customers and foreign PEPs. (UIF Resolution No. 49/2024, Section 12.)

A group may appoint one Compliance Officer for several group companies that are themselves obligated entities under Section 20 of Law No. 25,246, provided the monitoring tools give the officer timely access to all necessary information. In that case, the officer must form part of the governing body or highest authority of each obligated entity. This option does not generally permit an offshore officer with no formal position in the Argentine PSAV to act as the local Compliance Officer. (UIF Resolution No. 49/2024, Section 13.)

The PSAV must also establish an AML Committee chaired by the Compliance Officer and involving senior managers whose functions relate to financial-crime risk. The provider may dispense with the committee where its organizational structure makes effective implementation impracticable, but the governing body must document that decision and its reasons, and the Compliance Officer assumes the committee's responsibilities. (UIF Resolution No. 49/2024, Section 14.)

Customer Identification and Verification

The PSAV must identify and verify every customer, understand the intended purpose and nature of the relationship, conduct continuing due diligence and monitor transactions against the customer's activity and assigned risk. Identification must occur before the customer begins operating, and the provider may not open or maintain anonymous accounts or accounts under false or fictitious names. Failure to complete the required due diligence prevents the PSAV from beginning or continuing the relationship and requires an assessment of whether a suspicious transaction report should be filed. (UIF Resolution No. 49/2024, Sections 21 and 32.)

Remote onboarding must use rigorous biometric techniques that are storable, auditable and protected from manipulation. The biometric factor must be obtained from a living human present during the identification process, and automated verification is permitted only where the provider can demonstrate performance at least equivalent to human review. The external independent reviewer must expressly assess the reasonableness and operating effectiveness of the remote-identification procedure. (UIF Resolution No. 49/2024, Section 22.)

For individuals, the PSAV must collect and verify identity information, nationality, date and place of birth, tax or identification number where applicable, address, contact information, principal occupation and PEP status. For legal entities, it must verify formation and registration documents, tax identification, legal address, business activity, representatives, governing-body members, ownership and ultimate beneficial owners. (UIF Resolution No. 49/2024, Sections 23 and 24.)

Beneficial Ownership, PEPs and Terrorism Screening

The PSAV must identify and continuously know the ultimate beneficial owners of its customers and apply the applicable UIF rules on PEPs and terrorist-financing prevention. Customers, beneficial owners and relevant transfer recipients must be screened against RePET and the lists and measures applicable under Argentina's implementation of United Nations Security Council decisions. (UIF Resolution No. 49/2024, Sections 8, 12, 23 and 24; CNV Rules, Title XI, Section I, Section 1.)

Foreign PEPs are expressly treated as high-risk customers. The Compliance Officer must approve the beginning of the relationship and its continuation if an existing customer later becomes or is identified as a foreign PEP. Other PEP relationships must be managed under the current UIF PEP rules and reflected in the PSAV's risk methodology. (UIF Resolution No. 49/2024, Sections 12, 26 and 29; UIF Resolution No. 35/2023.)

Customer Risk Classification

Every customer must be classified and segmented according to risk. UIF Resolution No. 49/2024 contemplates low, medium and high-risk categories, with simplified, standard or enhanced due diligence applied according to the assigned level. Relevant factors include the customer's type and activity, source of funds, expected and actual transaction volume, nationality, residence, geographic exposure, products used and distribution channels. (UIF Resolution No. 49/2024, Sections 26 to 29.)

The resolution identifies several circumstances associated with higher risk, including complex ownership chains, customers operating with third-party funds, SAS entities, professional arbitrage activity and P2P transfers. A listed factor does not necessarily require rejection of the customer, but it must be reflected in the risk classification, due diligence and monitoring controls. (UIF Resolution No. 49/2024, Section 26.)

For medium-risk customers, the PSAV must obtain evidence concerning economic activity and the origin of income, funds or assets. For high-risk customers, the provider must obtain further supporting evidence, inquire into the purpose of the relationship and transactions, investigate relevant adverse history and intensify monitoring throughout the relationship. High-risk files must be updated at least annually, medium-risk files at least every three years and low-risk files at least every five years, subject to the risk-based qualifications established by Section 30. (UIF Resolution No. 49/2024, Sections 28 to 30.)

Transaction Monitoring and Blockchain Analytics

The PSAV must establish a prospective transaction profile for each customer and conduct continuous monitoring to determine whether actual operations remain consistent with the customer's known activity, financial circumstances and risk level. Monitoring must use control rules and automated alerts, and the methodology used to define the rules and parameters must be documented and kept confidential. (UIF Resolution No. 49/2024, Sections 33 and 34.)

The regulation identifies crypto-specific warning signs such as sequential or simultaneous transfers without economic justification, unusual transaction volumes, structuring, third-party account funding, transfers among related persons without justification, multiple accounts associated with the same device, transactions designed to impair traceability or increase anonymity, and exposure to addresses or services classified as high risk by tracing tools. Every unusual operation must be analyzed and recorded, including the alert, investigation, measures taken and reasoned final decision. (UIF Resolution No. 49/2024, Sections 34 and 35.)

UIF Resolution No. 49/2024 defines blockchain tracing tools but does not mandate a named vendor or a single technical methodology. The PSAV must select tools and controls appropriate to its supported blockchains, products, customers and risk tolerance and must be able to explain how relevant on-chain exposure affects alerts, customer classification and transaction decisions. (UIF Resolution No. 49/2024, Sections 2 and 34.)

The Travel Rule

PSAVs must identify the originator and beneficiary of virtual-asset transfers covered by the travel rule, applying the FATF standards in the manner established by the UIF for the exchange and validation of that information. UIF Resolution No. 49/2024 does not itself establish a domestic monetary threshold or prescribe the technical protocol through which PSAVs must exchange the information. Until the UIF adopts additional implementation rules, the PSAV should design its transfer procedures around the identification obligation in Section 37 and document the technical solution, counterparty controls and risk-based treatment it applies. (UIF Resolution No. 49/2024, Section 37.)

The rule should be built into the transfer architecture rather than treated solely as a post-transaction compliance review. The PSAV must determine when the counterparty is another regulated provider, what information must accompany the transfer, how the information will be validated and what controls apply to transfers involving self-custodied wallets.

Suspicious Transaction Reporting

Every suspicious operation must be reported to the UIF. The report must be reasoned, contain sufficient facts and supporting information and explain why the operation is considered suspicious. Once the PSAV concludes that a transaction is suspicious for money laundering, it must submit the report within twenty-four hours, and no later than ninety calendar days after the attempted or completed operation. Reports concerning terrorist financing or proliferation financing must be filed within twenty-four hours of the attempted or completed transaction. (UIF Resolution No. 49/2024, Section 36.)

Suspicious transaction reports are confidential. The customer and other unauthorized persons cannot be informed of the report, and external reviewers may assess the operation of the alert and reporting system only through information that does not identify the persons involved. (UIF Resolution No. 49/2024, Section 36(d).)

Systematic Reporting

In addition to event-driven suspicious transaction reports, the PSAV must make systematic reports through the UIF's reporting system. These include: (a) monthly reporting of virtual-asset transactions equal to or greater than six minimum monthly wages; (b) monthly reporting of customer additions and removals; and (c) an annual systematic report containing general, corporate, accounting, business and customer information. (UIF Resolution No. 49/2024, Section 39.)

The monthly reports must be submitted between the first and fifteenth day of each month for the preceding calendar month. The annual systematic report must be submitted between January 2 and March 15 for the preceding calendar year. Because the threshold for transaction reporting is expressed in minimum monthly wages rather than a fixed peso amount, the operational system must apply the legally current value for the relevant reporting period. (UIF Resolution No. 49/2024, Section 39.)

Independent Review, Internal Audit and Training

The AML system is evaluated at two levels. An independent external reviewer must issue an annual report on the quality and effectiveness of the system and electronically communicate the results to the UIF within 120 business days after the deadline for filing the risk self-assessment. The PSAV's internal audit function must also include AML matters in its annual program. Identified deficiencies must be accompanied by proposed improvements and implementation deadlines and reported to the Compliance Officer and governing body. (UIF Resolution No. 49/2024, Section 19.)

The PSAV must maintain an annual training plan covering directors, managers, employees and relevant contractors according to their functions and exposure to risk. New directors, managers and employees must receive training on the existing AML system within sixty business days after joining. Evidence of training and assessments must remain available to both the UIF and CNV. (UIF Resolution No. 49/2024, Section 18.)

Recordkeeping

Transaction documents must be retained for at least ten years from the operation and must permit reconstruction of the transaction, including amounts, currencies and types of virtual assets. Customer, beneficial-owner, due-diligence and commercial-correspondence records must also be retained for at least ten years from termination of the relationship or completion of the occasional transaction, whichever occurs later. The records must be maintained digitally, protected from unauthorized access and backed up in the same type of medium. (UIF Resolution No. 49/2024, Section 17.)

Reliance on Third Parties and Group Systems

A PSAV may rely on another obligated entity for customer and beneficial-owner identification and for understanding the purpose and nature of the relationship, but only if the conditions in Section 16 are met. The PSAV must obtain the relevant information immediately, ensure that supporting records will be supplied without delay, verify that the third party is regulated and supervised, document the arrangement and protect personal data and confidentiality. Responsibility for due diligence remains with the PSAV. (UIF Resolution No. 49/2024, Section 16.)

Group entities that are themselves obligated subjects may enter into reciprocity agreements to share customer files with the customer's express authorization. The arrangement must protect personal data and secrecy and cannot be extended to group companies that are not obligated subjects. A multinational group must therefore examine whether its centralized KYC repository and offshore access model satisfy the Argentine limitations on intragroup sharing. (UIF Resolution No. 49/2024, Section 13.)

Where the PSAV or its group has majority-owned branches, subsidiaries or affiliates abroad, the AML system must be implemented effectively across those entities with adequate intragroup information flows. For foreign operations, the group must apply the more stringent of the Argentine and foreign standards to the extent permitted by the foreign jurisdiction and document material differences between the applicable rules. (UIF Resolution No. 49/2024, Section 15.)

AIF Reporting Under General Resolution No. 1139/2026

General Resolution No. 1139/2026 requires PSAVs to transmit ten categories of AML information through the CNV's AIF platform: (a) beneficial owners; (b) principal and alternate Compliance Officers; (c) company identification and group reciprocity agreements; (d) the AML manual; (e) the risk self-assessment; (f) the internal-control report; (g) the risk-tolerance statement; (h) customer classification and segmentation; (i) transaction-monitoring information; and (j) PEP information. Each item is submitted through the corresponding LAV form identified in the resolution. (CNV Rules, Title XI, Section I, Section 2, and AIF reporting forms, as incorporated by CNV General Resolution No. 1139/2026.) We analyzed the new regime in detail in our note on General Resolution No. 1139/2026.

The update periods differ according to the information. Beneficial-owner changes must be reported within thirty calendar days; Compliance Officer information must be updated within five days after UIF registration; reciprocity agreements, customer segmentation, monitoring and PEP information must be updated every six months; changes to the AML manual must be filed within ten calendar days; the risk assessment and risk-tolerance statement are updated annually under the UIF timetable; and the internal-control report must be filed within ten calendar days after it is communicated to the Compliance Officer and AML Committee. (CNV Rules, Title XI, Section I, Section 2.)

The AIF obligation does not replace reporting to the UIF. It gives the CNV direct access to specified elements of the PSAV's AML structure for its own supervisory role. The documents submitted to the UIF, CNV and corporate governing body should therefore use the same customer segmentation, risk methodology, ownership information and description of the operating model.

CNV and UIF Supervision

The UIF sets and enforces the PSAV's core AML duties, receives systematic and suspicious transaction reports and may apply the sanctions provided in Law No. 25,246. The CNV supervises the PSAV as the regulator of the registered activity, receives the AIF filings required by General Resolution No. 1139/2026 and may use AML deficiencies or UIF sanctions when assessing whether the PSAV continues to satisfy the conditions supporting its registration. (UIF Resolution No. 49/2024, Section 40; CNV Rules, Title XI, Section IV, Section 12.)

An AML failure can therefore produce consequences in both regimes. It may lead to UIF enforcement under Law No. 25,246 and may also affect the continuation of the CNV registration where the failure indicates that the provider or its responsible persons no longer meet the applicable integrity or continuing-compliance standards.

The Registration Process Step by Step

PSAV registration is a two-platform administrative process supported by a substantially complete regulatory file. The application begins through the CNV website and the federal Trámites a Distancia platform, or TAD, while the applicant later uploads the prescribed regulatory forms through the CNV's Autopista de la Información Financiera, or AIF. The CNV reviews the corporate, financial, operational, technology, custody and compliance information before issuing an administrative decision granting or denying registration. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6; CNV, PSAV Registry Frequently Asked Questions, Question 4.)

Step 1: Confirm the Regulatory Perimeter and Categories

The first step is to determine which entity will perform each function and which PSAV categories apply. The analysis should identify: (a) the entity contracting with the customer; (b) the entity receiving fiat currency or virtual assets; (c) the entity controlling the exchange, transfer or custody function; (d) any third-party providers involved in the flow; and (e) the territorial connection that brings the foreign group within the Argentine regime.

The resulting analysis must be reflected in the registration application. Section 6 requires the applicant to identify the activities falling within the statutory PSAV definition and each registry category corresponding to those activities. An incomplete category analysis can affect the minimum net worth calculation, the custody documentation, the systems report and the manuals that must accompany the filing. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6(b)(10), 8, 9 and 20.)

The applicant should complete this classification before finalizing its customer contracts or local corporate purpose. The business description used in the TAD filing, AIF forms, terms of service, technology report and AML risk assessment should describe the same operating model.

Step 2: Establish the Argentine Applicant

A foreign group must establish the entity that will apply for registration before it can submit a complete Section 6 filing. The applicant must be: (a) an Argentine SA or SRL involving a foreign shareholder registered under Section 123 of Law No. 19,550; or (b) the foreign company acting through a branch, establishment or permanent representation registered under Section 118. The applicant must already have a CUIT, registered constitutional documents and a corporate purpose that expressly or implicitly includes the PSAV activities for which registration is requested. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 6(b)(1) to (3).)

The local entity should also have its registered office, operational addresses, Argentine telephone number, regulatory email address, customer-complaints email address and institutional website using a ".ar" domain. The website does not need to be commercially active before approval, but the applicant must be able to identify the domain and the channels through which it intends to operate. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(5) to (9).)

Step 3: Fix the Ownership and Management Structure

The applicant must identify its shareholders, directors, managers, supervisory body members where applicable, local branch representatives and certain general or special managers. It must provide the corporate records evidencing their appointment and the allocation of offices. Changes to the governing or supervisory bodies after filing must be reported within ten business days. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(11) and (12).)

The applicant must also prepare criminal-record certificates and AML declarations for the persons specified in Section 6. The CNV separately reviews directors, administrators, persons performing management functions and ultimate beneficial owners under the integrity and solvency regime introduced by General Resolution No. 1139/2026. Beneficial owners are persons holding at least 10 percent of capital or voting rights or otherwise exercising ultimate direct or indirect control. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(13) and (14); CNV Rules, Title XI, Section IV, Sections 9 to 11.)

This review should be performed internally before filing. A criminal, regulatory, commercial or insolvency issue affecting a director or controlling individual may delay the application or require a change in the proposed structure. Replacing an individual after submission can require updated corporate documents, declarations and a renewed CNV assessment.

Step 4: Appoint the Required Regulatory Officers

The applicant must identify its Regulatory Compliance and Internal Control Officer and its Customer Relations Officer. It must separately appoint a principal and alternate AML Compliance Officer under UIF Resolution No. 49/2024 and register those appointments with the UIF. These functions should be assigned before submission because the regulatory manuals, reporting lines and governing-body resolutions must identify the persons responsible for implementation. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 6(b)(15) and (16), 21 and 29; UIF Resolution No. 49/2024, Sections 11 and 12.)

The applicant should define whether any individual will hold more than one function and document why the resulting allocation preserves autonomy, access to information and effective control. The CNV officer and the UIF officer have different mandates, even where the company proposes to appoint the same person to both positions.

Step 5: Capitalize the Applicant and Obtain the Accounting Evidence

The applicant must satisfy the minimum net worth corresponding to its most demanding category. It must submit its latest annual financial statements, or financial statements covering the period since incorporation if it is newly formed, audited by an independent public accountant and filed with the competent corporate authority. Where the statements are more than eight months old when the complete application is submitted, an additional independent accountant's certification is required. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(18).)

The net worth must be measured as of a date no more than two months before the filing and converted into US-dollar equivalent using the exchange rate provided under BCRA Communication "A" 3500, as amended. The accounting evidence should be timed against the expected filing date because an avoidable delay can cause the certification to become stale and require an updated report. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(18).)

The applicant's governing body, or the local representatives of a branch, must also adopt a resolution declaring that the entity has its own administrative organization adequate to provide the proposed PSAV services. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(19).)

Step 6: Prepare the Operating and Technology File

Before filing, the applicant should have the principal components of its operating framework in final or near-final form. This includes: (a) procedure manuals for exchange, orders, transfers and custody, as applicable; (b) the systems description and IT expert report; (c) cybersecurity and information-security policies; (d) the custody architecture and wallet diagram for Category 4 applicants; (e) the Code of Conduct; (f) risk-management and complaints procedures; and (g) customer-facing disclosures concerning fees, virtual-asset risks and the service model. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 11 to 17 and 24 to 32.)

Section 6 expressly requires the IT expert report, the custody-system details where applicable, information concerning third-party agreements and a sworn statement by the legal representative or attorney-in-fact confirming compliance with all requirements applicable to the proposed activities. The CNV may request any additional information necessary to evaluate the application. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(20), final paragraphs.)

The sworn statement should not be signed while material parts of the operating framework remain merely aspirational. The company should be able to demonstrate how each required control operates, who is responsible for it and which system or procedure produces the relevant evidence.

Step 7: Prepare the AML Framework

The AML workstream should proceed in parallel with the CNV operating file. Before launch, the applicant must have an AML manual, risk-assessment methodology, initial self-assessment, risk-tolerance statement, customer segmentation, KYC procedures, transaction-monitoring rules, suspicious transaction reporting procedures, travel-rule controls, training arrangements and internal-review mechanisms. (UIF Resolution No. 49/2024, Sections 3 to 19 and 21 to 39.)

The documents should describe the Argentine entity's own customers, products, jurisdictions, channels and transaction flows. Where the applicant relies on group-level systems or policies, the local documents should explain which functions are centralized, how the Argentine Compliance Officer obtains information and how local rules prevail where the group standard is less demanding.

General Resolution No. 1139/2026 requires the PSAV to upload specified AML information through AIF, including beneficial ownership, Compliance Officers, the AML manual, risk self-assessment, internal-control report, risk tolerance, customer segmentation, transaction-monitoring information and PEP information. (CNV Rules, Title XI, Section I, Section 2.)

Step 8: Complete the CNV Web Form and Start the TAD Filing

Since May 26, 2025, new PSAV registration applications must be submitted exclusively through TAD. The applicant first completes the PSAV registration form available through the CNV website. It then initiates the corresponding TAD proceeding and attaches the web form and the initial documentation required under Section 6.

TAD is the formal administrative file. Notices, requests for additional information and the final decision are delivered through that proceeding. The person initiating the filing must therefore have sufficient corporate authority to act for the applicant and must monitor the TAD electronic address throughout the process.

The information must be true, complete and current on the filing date. The CNV may require further material even when the applicant has submitted every document expressly listed in Section 6. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6, final paragraphs.)

Step 9: Obtain AIF Access and Submit the Regulatory Forms

The CNV first reviews the initial TAD package. If the preliminary documentation is sufficient to continue and the CNV has no initial observations, it sends instructions for obtaining the Operator/Signatory credentials required to access AIF. The applicant then uploads the applicable information and documents through the AIF forms.

After completing the AIF filings, the applicant must access its AIF submission history and download the PDF titled "Listado de Presentaciones CNV," which records the forms submitted. That PDF must be added as supplementary documentation to the original TAD proceeding. The TAD and AIF components therefore form a single application file: TAD contains the administrative proceeding, while AIF contains the standardized regulatory data and documents.

The applicant should keep an internal filing matrix identifying each Section 6 requirement, the corresponding TAD attachment, the applicable AIF form, the responsible preparer and the date through which the information remains current.

Step 10: Respond to CNV Observations

Once the TAD and AIF stages are complete, the CNV analyzes the full file. If it identifies inconsistencies, missing information or substantive concerns, it issues a formal request through TAD. The response may require revised documents, additional evidence, explanatory memoranda, updated certificates or changes to the applicant's proposed structure.

The most consequential observations are unlikely to be resolved by supplying a missing form alone. A question concerning control of customer assets may require changes to the custody design and customer agreement. A concern regarding local organizational substance may require reallocating functions from the foreign parent to the applicant. A discrepancy in beneficial ownership may require corrected corporate and AML filings.

Responses should address the CNV's question directly and update every document affected by the answer. Submitting an amended custody diagram without updating the IT report, procedure manual and terms of service can create a new inconsistency.

Step 11: Registration Decision

If the application is approved, the CNV issues an administrative disposition assigning the applicant a PSAV registration number. The disposition and notification are delivered through TAD. If the application is denied or additional information is required, the corresponding notice is also issued through TAD.

Registration is not effective merely because the applicant has submitted its forms or because the TAD proceeding remains pending. Section 1 requires registration before the applicant begins the covered activities, and Section 2 requires an unregistered person to refrain from performing them in Argentina. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 2.)

After approval, the PSAV must display the following registration statement on its website, application and social-media channels: "Inscripto bajo el N° [registration number] en el Registro de PSAV de la CNV (República Argentina)." The company should also complete its customer disclosures, activate its complaints channel and verify that its operational systems correspond to the version approved by the governing body and presented to the CNV. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 5.)

How Long Does PSAV Registration Take?

The complete market-entry process for a foreign company generally takes between five and eight months. This period includes preparation and legalization of foreign corporate documents, registration under Section 123 or Section 118 of the General Companies Law, incorporation and tax registration of the Argentine applicant where applicable, preparation of the financial, technology and AML documentation, submission through TAD and AIF, and response to CNV observations.

The rules do not establish a guaranteed period within which the CNV must decide a complete PSAV application. The total schedule depends primarily on the ownership chain, availability of foreign documents, corporate route, PSAV categories, custody architecture and the applicant's readiness to demonstrate that its systems and controls are operational.

Some of these workstreams can proceed concurrently. The technology report, custody analysis, AML methodology and draft manuals can be prepared while the local corporate registration is pending, provided that the intended ownership, applicant and operating model have already been approved.

Government Fees and External Costs

Starting the PSAV registration proceeding currently carries no application fee. Once registered, the PSAV becomes subject to the CNV's annual supervision and control fee. For the 2026 fiscal year, the fee is ARS 13,360,000 for legal-entity PSAVs and ARS 5,344,000 for individual PSAVs. The payment period applicable to the 2026 fee was February 3 through February 9, 2026. The CNV may revise the amount and payment schedule for later fiscal years. (Ministry of Economy Resolution No. 1/2026, setting the CNV 2026 supervision and control fee schedule.)

The government fee is separate from the external costs of establishing the applicant and preparing the filing. A foreign group should budget for: (a) corporate registry fees; (b) notarial, apostille and legalization costs; (c) public translations; (d) accounting certifications and audits; (e) the IT expert report and annual systems audit; (f) local directors, managers or representatives where required; and (g) compliance personnel and technology. These costs depend materially on the home jurisdiction, ownership chain, corporate route, PSAV categories and custody model and should therefore be estimated for the specific project rather than stated as a single registration price.

Ongoing Obligations After Registration

PSAV registration creates a continuing compliance obligation rather than a one-time approval. The provider must preserve the financial, corporate, technical, operational and integrity conditions supporting its registration, submit periodic information through AIF, report specified changes within short deadlines and continue complying with the UIF framework. Failure to maintain those conditions can lead to sanctions, cancellation or expiration of the registration. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 39 to 41; CNV General Resolution No. 1139/2026, Title XI, Section IV, Section 12.)

Maintaining Minimum Net Worth

The PSAV must maintain the minimum net worth applicable to its registered category or categories throughout the registration period. Customer virtual assets do not count toward the provider's net worth because they must be treated as customer property and recorded in memorandum accounts. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 9, 10 and 16.)

If the annual financial statements show that net worth has fallen below the applicable minimum, the PSAV must immediately disclose the deficiency to the CNV as a material event. Within ten business days, it must submit the measures it intends to adopt to restore compliance. The rule requires a remediation plan but does not grant an automatic ten-day safe harbor during which the provider may remain undercapitalized without regulatory consequences. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 10.)

A provider relying on the 50 percent reduction available to certain lower-volume Categories 1, 2, 3 and 4 PSAVs should monitor the relevant transaction or custody volume continuously. Crossing the applicable threshold changes the minimum net worth requirement and may require additional capitalization before the next financial reporting date. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 9.)

Monthly AIF Reporting

Within fifteen calendar days after the end of each calendar month, the PSAV must submit through AIF: (a) the number of customers, divided between individuals and legal entities; (b) the monthly transaction volume, stated as a total US-dollar amount; (c) the ten virtual assets most frequently traded or held in custody, including the quantity of each asset; and (d) for custody activity, the total quantity of each virtual asset held. The report applies according to the categories in which the PSAV is registered. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 39(b).)

The regulation does not define every calculation convention required for complex products. A PSAV should adopt a documented and consistently applied methodology addressing internal transfers, cancelled transactions, transactions between customers of the same platform, asset valuation and the treatment of operations performed through third-party systems.

Annual CNV Reporting

A registered PSAV must submit two annual control reports within seventy calendar days after the end of each calendar year. The first is the annual systems audit required by Section 20, covering operation, security, continuity, immutability of records, backups, proof of reserves and the other systems requirements applicable to the provider. The second is the report issued by the Regulatory Compliance and Internal Control Officer concerning the examinations performed during the year. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 20, 21 and 39(c).)

A legal-entity PSAV must also file its annual financial statements and external auditor's report through AIF. The filing is due within five days after the statements are submitted to the competent Public Registry or within five days after the applicable corporate filing deadline expires, whichever occurs first. For the regulatory net worth calculation, the provider must use the US-dollar value at the end of the calendar year and the exchange rate established under BCRA Communication "A" 3500, as amended. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 39(c)(3).)

The governing body must consider the annual systems audit and record in its minutes the audit conclusions, recommendations, its own analysis and any corrective measures adopted. A branch registered under Section 118 of Law No. 19,550 must record the same matters in the special book maintained by its local representatives. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 20.)

Updating Corporate and Regulatory Information

Changes to directors, managers, supervisory body members or local branch representatives must be reported within ten business days. New directors, administrators, persons performing management functions and beneficial owners must also be notified for the integrity and solvency assessment required by General Resolution No. 1139/2026. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6(b)(12); CNV General Resolution No. 1139/2026, Title XI, Section IV, Sections 9 and 10.)

Other information filed through AIF that has no specific periodic deadline must be updated within five days after the relevant change. This general rule can apply to operational addresses, contact information, platforms, websites, regulatory officers, categories and other registration data, subject to any more specific deadline established elsewhere in the rules. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 39, final paragraph.)

A Category 4 PSAV must keep its custody information current through AIF. This includes operational wallet addresses, identification of proprietary and third-party custody arrangements, blockchain networks, wallet types and the applicable key-control structure. The wallet information is nonpublic, but the provider must continue publishing proof of reserves through its website or application. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 15 and 39(a).)

Changes to Third-Party Arrangements

A PSAV must report referral agreements through AIF within five days, identifying the execution date, term and relevant registered agent or third party. Advertising produced under a referral arrangement must identify the registered PSAV and accurately describe the services being provided. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 34.)

Agreements through which the PSAV integrates operations with a third party or delegates a function must also be reported within five days after execution. The report must identify the third party, its jurisdiction, the service and the agreement's duration. Termination must be reported immediately as a material event. Delegation does not release the registered PSAV from responsibility for the outsourced function or the third party's performance. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 35.)

For an agreement with a foreign entity performing PSAV-type functions, the foreign entity must be regulated in a jurisdiction that is not listed as noncooperative for tax-transparency purposes and must be subject to AML regulation and supervision consistent with FATF standards. The PSAV should verify those conditions at onboarding and monitor whether they continue to be satisfied during the relationship. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 35.)

Customer-Facing Information

The PSAV must continue displaying its CNV registration legend on its website, application and social-media accounts. It must maintain an accessible customer-complaints channel, publish its pricing, costs and commissions, and ensure that advertising is clear, fair and not misleading. The CNV may order the modification or suspension of noncompliant advertising. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 5 and 29 to 32.)

The provider must also publish the required virtual-asset risk disclosures and make available a white paper or equivalent information concerning each asset offered through the platform. An asset launched less than ninety days earlier must be displayed with the additional warnings and separate presentation required by Section 37. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 36 and 37.)

These disclosures should be updated when the product, custody arrangement, fees, execution mechanics or supported assets change. A disclosure that was accurate at registration may become misleading if the provider changes its operating model without revising its website and customer terms.

Continued Custody and Asset-Segregation Controls

Category 4 PSAVs must continuously preserve the separation between proprietary virtual assets and customer virtual assets in internal records, accounts maintained with other PSAVs and third-party wallets. Customer assets cannot be recorded as assets of the PSAV or used to satisfy its net worth requirement. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 16.)

Fiat funds linked to customer transactions must also remain separated from funds used for the PSAV's proprietary business. A PSAV that holds or administers customer fiat or virtual assets cannot use them for its own account and must transfer or manage them according to the customer's express instructions. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 18 and 19.)

The annual systems audit does not replace day-to-day control. Changes to wallet infrastructure, custodians, signing thresholds, key-recovery processes or access roles should undergo internal approval and risk assessment before implementation and should be reflected promptly in the information-security policies and AIF filings.

AML Updates Through AIF

General Resolution No. 1139/2026 requires the PSAV to maintain ten categories of AML information through AIF. Beneficial-owner changes must be reported within thirty calendar days. Compliance Officer information must be updated within five days after UIF registration. Reciprocity agreements, customer segmentation, transaction-monitoring information and PEP information must be updated every six months. (CNV General Resolution No. 1139/2026, Title XI, Section I, Section 2.)

Changes to the AML manual must be submitted within ten calendar days. The risk self-assessment and risk-tolerance statement must be updated annually according to the UIF timetable. The internal-control report must be filed within ten calendar days after it is communicated to the Compliance Officer and the AML Committee. These CNV filings do not replace the PSAV's separate reports and registrations with the UIF. (CNV General Resolution No. 1139/2026, Title XI, Section I, Section 2.)

Continuing Integrity and Solvency

The integrity and solvency review does not end when the registration is granted. The CNV may reassess the relevant persons after new appointments or other developments and requires the provider to preserve the conditions on which its registration was based. Loss of those conditions results in expiration of the registration under Section 12 of the regime introduced by General Resolution No. 1139/2026. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Sections 10 to 12.)

The CNV will give particular weight to communications from the UIF concerning sanctions imposed for AML, terrorist-financing or proliferation-financing violations. A material AML enforcement matter can therefore affect both the UIF relationship and the continuation of the PSAV registration. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Section 12.)

Record Retention

The PSAV must retain accounting records, customer identity records, relevant customer communications and all evidence needed to reconstruct the services and transactions performed for customers for at least ten years. The provider must protect those records against destruction, loss, misuse and unauthorized disclosure. Outsourcing storage does not transfer responsibility for compliance. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 38.)

The CNV recordkeeping obligation should be coordinated with the ten-year retention duties under UIF Resolution No. 49/2024. The retention architecture must preserve accessibility, integrity and retrievability across customer, transaction, blockchain and internal-investigation records.

Annual Supervision and Control Fee

Registered PSAVs must pay the CNV's annual supervision and control fee. For the 2026 fiscal year, the fee is ARS 13,360,000 for legal entities and ARS 5,344,000 for individuals. The payment period applicable to the 2026 fee was February 3 through February 9, 2026. Because the amount and payment period are subject to regulatory adjustment, both must be checked against the CNV's current fee schedule before payment.

CNV Interpretive Criterion No. 100 addressed a narrow transitional issue affecting the 2025 fee. Where a foreign PSAV already registered under the former regime paid the 2025 annual fee and transferred its Argentine activity to a newly registered local company under General Resolution No. 1058/2025, the CNV treated the prior payment as covering the local successor for 2025. The criterion expressly limits that treatment to the 2025 fiscal year. From 2026 onward, the Argentine company is subject to the general annual payment regime.

Interpretive Criterion No. 100 should therefore not be described as a general group exemption, a permanent rule against duplicate fees or a credit available whenever a business changes legal entities. Its function was to prevent a second 2025 charge during the transition from the former foreign-company registration model to the local structures required by General Resolution No. 1058/2025.

Operating Without Registration

A person that is required to register as a PSAV may not perform covered activities in Argentina before the CNV grants the registration. This prohibition applies equally to Argentine operators and foreign companies caught by one of the territorial connections in Section 3 of General Resolution No. 1058/2025. Filing an application does not authorize the applicant to operate while the proceeding is pending. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 2.)

The Registration Must Precede the Activity

General Resolution No. 1058/2025 requires registration "prior to" carrying out the regulated activity. An Argentine company must obtain registration before performing any activity included in the PSAV definition. A foreign company must do the same when it directly performs a covered activity under any of the territorial modalities established by Section 3, using the local corporate structure required by Section 1. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 1.)

Section 2 reinforces that rule by directing every unregistered person to refrain from conducting PSAV activities in Argentina. The prohibition does not depend on whether the provider has already received a CNV warning, whether the business is profitable, or whether the provider considers its application likely to be approved. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 2.)

A company preparing an application must therefore distinguish between activities needed to establish the business and the actual provision of regulated services. Incorporating the local entity, hiring personnel, configuring systems, negotiating banking arrangements and testing internal controls do not necessarily constitute the provision of a PSAV service to customers. Opening accounts for Argentine residents, accepting customer funds, executing exchanges, transferring customer assets or assuming custody before registration can breach Sections 1 and 2.

Filing an Application Does Not Create Interim Authorization

Neither General Resolution No. 1058/2025 nor the CNV's application procedure creates a provisional registration merely because a TAD filing has been initiated or AIF information has been uploaded. Registration becomes effective only when the CNV issues the corresponding administrative decision and assigns the applicant a PSAV registration number. The requirement to register before operating and the express prohibition applicable to unregistered persons mean that a pending applicant must remain outside the regulated activity until approval. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1, 2, 5 and 6.)

The same reasoning applies where an offshore company has already served Argentine customers and later creates a local applicant. The new application may provide a path toward future compliance, but it does not retroactively authorize the prior activity. This conclusion follows from the prospective wording of Sections 1 and 2, which require registration before the activity begins.

A group in that position should separately address: (a) cessation or restructuring of the existing Argentine-facing activity; (b) treatment of existing customers and assets; (c) preservation of records; (d) disclosures made to the CNV in the application; and (e) whether the prior conduct may require a specific explanation. The company should avoid presenting the local entity as a continuation of the offshore operation without explaining when the customer contracts, accounts and regulated functions will move to the registered applicant.

CNV Supervision and Enforcement Powers

Law No. 27,739 grants the CNV all of the supervisory, regulatory, inspection, enforcement and sanctioning powers contained in Section 19 of Law No. 26,831 with respect to PSAVs. The CNV may request information, conduct investigations and inspections, commence administrative enforcement proceedings, impose sanctions, seek judicial assistance and report suspected crimes. (Law No. 27,739, Section 37; Law No. 26,831, Sections 19 and 20.)

This authority is not confined to companies already registered. Section 2 expressly provides that unregistered activity is subject to sanctions under Section 37 of Law No. 27,739. Section 40 of General Resolution No. 1058/2025 separately applies the sanctions established by Title IV, Chapter I of Law No. 26,831 to breaches of the CNV's PSAV requirements, conditions and obligations. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 2 and 40; Law No. 27,739, Section 37.)

Website and Social-Media Blocking

When the CNV identifies a possible unlawful act by an unregistered PSAV, it may request that the specialized prosecutor's office or the competent court seek the immediate blocking of the provider's website URL, social-media username or other means through which it operates. The CNV rule does not state that the agency itself may unilaterally block the site. It contemplates a request to the prosecutorial or judicial authority with the relevant power. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 40.)

For a foreign platform, this measure can be more consequential than a monetary sanction. Blocking can interrupt customer access, prevent withdrawals through the ordinary interface and affect relationships with local payment providers, affiliates and commercial partners. A provider should therefore have a contingency procedure for customer communications and asset access if its Argentine-facing channels become unavailable.

The blocking provision refers to a "possible unlawful act," rather than requiring a final administrative sanction before the CNV may seek judicial intervention. The practical enforcement risk can therefore arise during an investigation and before the provider has completed all available administrative or judicial challenges. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 40.)

Administrative Sanctions

The sanctioning regime incorporated through Law No. 26,831 includes: (a) a warning, which may be accompanied by publication of the operative portion of the decision; (b) a fine ranging from ARS 100,000 to ARS 100 million, which may be increased to five times the benefit obtained or harm caused when either amount is greater; (c) disqualification of responsible individuals for up to five years; (d) suspension for up to two years; and (e) prohibition from acting within the regulated activity. The statute does not provide an automatic mechanism for updating the nominal monetary range. (Law No. 26,831, Section 132.)

Sanctions are not necessarily limited to the company. When individual responsibility is established, directors, administrators, supervisory body members and certain managers may be held jointly liable with the legal entity. In determining the sanction, the CNV must consider factors including the seriousness of the breach, the benefit obtained, the harm caused, the provider's operating volume and the conduct of the individual members of its governing and supervisory bodies. (Law No. 26,831, Section 133.)

An unregistered provider may also have separate exposure under the UIF regime if it qualifies as a PSAV and therefore as an obligated entity under Section 20(13) of Law No. 25,246. UIF sanctions for breaches of AML duties may include warnings, fines, disqualification of the Compliance Officer and a recommendation to the relevant regulator that an authorization be revoked or that responsible directors be disqualified. (Law No. 25,246, Section 24, as replaced by Law No. 27,739, Section 19.)

Denial of a Registration Application

The CNV may deny an application when the applicant does not meet the corporate, financial, operational or technical requirements of General Resolution No. 1058/2025. The CNV may also refuse registration when the relevant persons do not satisfy the integrity and solvency standards introduced by General Resolution No. 1139/2026. Under Section 8 of that regime, registration proceeds only for persons that, in the CNV's judgment, meet the applicable conditions. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 6; CNV General Resolution No. 1139/2026, Title XI, Section IV, Sections 6 to 11.)

For PSAVs, the specific idoneity requirement in Section 11(1) is currently suspended by the transitional provision in Article 4 of General Resolution No. 1139/2026. The CNV nevertheless reviews integrity and solvency, including criminal and regulatory background, PEP status, sanctions screening, unjustified defaults, economic judgments, bankruptcy proceedings and repeated attachments. Beneficial owners are reviewed for integrity. (CNV General Resolution No. 1139/2026, Article 4; Title XI, Section IV, Sections 9 to 11.)

Prior unregistered operation is not expressly listed as an automatic statutory ground for rejection. It may nevertheless become relevant to the CNV's assessment of the accuracy of the filing, the applicant's compliance history, its management and its ability to satisfy the regulatory conditions. Any statement concerning past operations must therefore be accurate and consistent with the customer, transaction and corporate records available to the regulator.

Revocation and Cancellation of an Existing Registration

General Resolution No. 1058/2025 uses "cancellation" for several different routes by which an existing registration ends. The CNV cancels the registration when: (a) the PSAV voluntarily requests withdrawal and declares that it will cease all covered activity in Argentina from the date of the request; (b) the CNV revokes the PSAV's authorization in exercise of its supervisory and sanctioning powers; or (c) the UIF requests cancellation because of failures to comply with its reporting regime, including failure to identify beneficial owners. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 41.)

Voluntary cancellation is not effective merely because the company has decided internally to leave the market. The person submitting the request must prove authority to act, make the required sworn statement and provide any supplementary information requested by the CNV. The company must state that it will cease conducting PSAV activities in Argentina from the filing date. A former PSAV may later submit a new application, but it must satisfy the rules then in force. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 41(a).)

Revocation under Section 41(b) is an enforcement outcome. It should be distinguished from a voluntary withdrawal and from the expiration of registration under General Resolution No. 1139/2026. Revocation follows the CNV's exercise of its regulatory, inspection and sanctioning powers under Law No. 26,831. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 41(b); Law No. 26,831, Section 19.)

Expiration for Loss of Integrity or Solvency

General Resolution No. 1139/2026 provides a separate consequence when an authorized person no longer preserves the conditions of idoneity, integrity and solvency supporting its registration. Failure to maintain the applicable conditions results in the expiration, or caducidad, of the CNV registration. For PSAVs, the currently applicable review must account for the transitional exclusion of the idoneity limb, but integrity and solvency remain continuing requirements. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Section 12, and Article 4.)

Expiration is conceptually different from an administrative fine. The former concerns the provider's continuing eligibility to remain registered. A fine sanctions a breach. The same events may support both consequences if they show a regulatory violation and also demonstrate that the provider or its responsible persons no longer satisfy the conditions required for registration.

The CNV must give particular weight to communications received from the UIF concerning AML sanctions. A material UIF proceeding can therefore create direct monetary and personal consequences under Law No. 25,246 and may also threaten the continuation of the PSAV registration. (CNV General Resolution No. 1139/2026, Title XI, Section IV, Section 12.)

Foreign Companies Participating in Argentine Events

General Resolution No. 1058/2025 contains a narrow exception allowing an unregistered foreign company that performs PSAV activities abroad to sponsor an international event held in Argentina. The foreign sponsor must: (a) inform attendees that it is not registered with the CNV; (b) refrain from conducting PSAV activities in Argentina, including calls to invest in virtual assets; and (c) state at any event stand that it is not registered and cannot offer services to Argentine residents. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Section 42.)

This provision confirms that brand presence at an international event can be separated from the provision of services, but only within strict limits. It does not authorize account opening, customer solicitation, transaction execution or investment promotions directed at Argentine residents. A foreign sponsor should review presentations, QR codes, referral links, promotional materials and staff instructions before the event to ensure that the activity remains within Section 42.

Practical Consequences Beyond the Administrative Proceeding

Operating without registration can create difficulties beyond the CNV proceeding. A bank, PSP, custodian, liquidity provider or commercial counterparty may require proof that the company is authorized to perform the proposed Argentine activity. Customer agreements may also contain representations concerning regulatory status that become inaccurate once the Argentine registration obligation is triggered.

These consequences follow from the provider's inability to lawfully perform the regulated activity before registration, although their contractual treatment depends on the relevant agreement. A company should not assume that obtaining registration later will automatically restore terminated payment channels, validate prior regulatory representations or resolve customer claims arising during the unregistered period. (CNV General Resolution No. 1058/2025, Title XIV, Chapter III, Sections 1 and 2.)

Tokenization and the Regulatory Sandbox

CNV General Resolution No. 1150/2026 expands Argentina's regime for the digital representation of securities and extends its regulatory sandbox through December 31, 2027. The regime does not permit companies to convert an unregulated token into a security or to avoid the public-offering rules. It allows eligible securities that have been validly issued under Argentine capital-markets law to be represented, offered, traded and held digitally through an approved structure involving registered PSAVs. (CNV General Resolution No. 1150/2026; CNV Rules, Title XXII, Chapter I, Sections 1 to 10 and 38.)

What General Resolution No. 1150/2026 Covers

The tokenization regime applies to specified categories of securities, including: (a) shares, including dual-listed shares; (b) corporate bonds; (c) CEDEARs; (d) debt securities and participation certificates issued by public-offering financial trusts meeting the conditions established by the rules; (e) units of eligible closed-end investment funds; (f) units of open-end exchange-traded funds; and (g) CEVA ETPs. General Resolution No. 1150/2026 also permits eligible shares, corporate bonds, financial-trust securities and closed-end fund units issued under the CNV's automatic public-offering authorization regimes to use the tokenization framework, subject to the specific conditions applicable to those regimes. (CNV Rules, Title XXII, Chapter I, Section 1, as amended by CNV General Resolution No. 1150/2026.)

The regime excludes securities classified as social, green, sustainable or sustainability-linked instruments. It also generally excludes foreign sovereign debt, except for sovereign securities issued by MERCOSUR member states and Chile. These exclusions relate to the tokenization framework and do not determine whether the underlying securities may otherwise be offered or traded under another applicable CNV regime. (CNV Rules, Title XXII, Chapter I, Section 1.)

The Digital Representation Does Not Create a New Security

The digital representation is an additional form of representation of an existing security. It does not create a second security, replace the underlying instrument or independently alter its legal terms. The security in its traditional certificated or book-entry form must have been validly authorized and issued, either before or at the same time as its digital representation. (CNV Rules, Title XXII, Chapter I, Sections 5, 7 and 10.)

The issuer must obtain CNV authorization for the digital representation. That authorization may be requested when the security is initially issued or later for an eligible security already in circulation. A subsequent digital representation does not require a second public-offering authorization for the underlying security, but it does require the issuer's corporate approval, the CNV's authorization of the representation and the disclosures prescribed by the tokenization rules. (CNV Rules, Title XXII, Chapter I, Sections 3, 4, 7, 11 and 12.)

The digital record must use distributed-ledger technology or another similar technology capable of providing security, immutability, verifiability, fungibility, integrity, transferability and traceability. The regime is technologically neutral, but the chosen architecture and smart contracts must satisfy the legal and operational restrictions imposed by the CNV. (CNV Rules, Title XXII, Chapter I, Sections 2, 5, 9 and 10.)

The Role of Registered PSAVs

Securities represented digitally under this regime may be offered, subscribed, traded and held through digital platforms or mobile applications administered by participating PSAVs. A participating PSAV must be a legal entity and must remain registered simultaneously in all five PSAV categories for as long as it participates in the digital representation. Registration in only the categories that correspond to the provider's ordinary business is insufficient for participation in this specific tokenization regime. (CNV Rules, Title XXII, Chapter I, Sections 11 and 14.)

The participating PSAV is responsible for the digital placement, transaction records, management of investor holdings, digital trading and custody functions assigned to it. It must maintain the infrastructure needed to identify investors, record their holdings, process economic and political rights, prevent market abuse, segregate customer assets and comply with the prudential custody requirements applicable under the general PSAV rules. (CNV Rules, Title XXII, Chapter I, Sections 13, 15, 19, 21, 23 and 26 to 32.)

The underlying security remains deposited in its traditional form with an authorized central securities depository agent, known as an ADCVN, in a specially identified account held for the benefit of the investors. One or more permitted entities act as the registered holder of the traditional securities, while the participating PSAV records and administers the corresponding digital holdings attributed to each investor. The structure therefore separates the registered holder of the underlying security from the investor holding its digital representation. (CNV Rules, Title XXII, Chapter I, Sections 5, 12, 15 and 21.)

Digital representations cannot be transferred or traded outside the participating PSAVs designated under the issuance documents or through decentralized protocols providing virtual-asset services. The smart contracts must prevent transfers that are incompatible with those restrictions. Where several PSAVs participate, their infrastructure must support interoperability and timely synchronization of investor and holding information. (CNV Rules, Title XXII, Chapter I, Section 5(e) and (f).)

Technology Providers That Are Not PSAVs

The specialized technology entity that generates and maintains the digital representation may, but need not, be registered as a PSAV. A provider that limits its role to supplying the distributed-ledger or similar technology used to generate the digital representation does not necessarily require PSAV registration. It must nevertheless have demonstrable experience, recognized standing and an organizational structure appropriate for the service. (CNV Rules, Title XXII, Chapter I, Sections 5(d) and 14.)

This exclusion is functional and limited. A technology company must register as a PSAV if it also performs an activity covered by Section 4 bis of Law No. 25,246, such as transferring, exchanging or holding virtual assets for customers. A contractual designation as a software or infrastructure provider will not control if the company's actual role includes a regulated PSAV function. (CNV Rules, Title XXII, Chapter I, Section 14.)

The issuance documents must identify the specialized technology entity, describe the distributed network, consensus protocol, coding standards, smart-contract architecture and cybersecurity mechanisms, and allocate responsibility for the entity's conduct and the maintenance and security of the smart contracts. Participating PSAVs are responsible for their own operational, placement, custody and digital-environment functions, but the rules do not automatically make them responsible for the separate conduct of the specialized technology entity. (CNV Rules, Title XXII, Chapter I, Sections 12, 22 and 23.)

The Regulatory Sandbox

The sandbox is the temporary legal framework under which the entire tokenization regime is being tested. It is not an individualized exemption under which a company may apply for relief from the PSAV, securities or AML rules. Participants must comply with the requirements of Title XXII and with the other CNV and UIF rules applicable to their functions. (CNV Rules, Title XXII, Chapter I, Sections 20, 29, 35, 36 and 38.) Our note on the tokenization sandbox expansion covers the background of the regime.

The sandbox remains in force through December 31, 2027. Digital representations validly created during that period remain valid afterward, but no new securities may be issued or newly represented digitally under the regime after that date unless the CNV extends or replaces it. At the end of the period, the CNV may continue, amend, expand, narrow or terminate the framework. (CNV Rules, Title XXII, Chapter I, Section 38, as amended by CNV General Resolution No. 1150/2026.)

What the Regime Means for Foreign Crypto Companies

General Resolution No. 1150/2026 creates a potential additional business line for foreign exchanges, custodians and tokenization-technology providers entering Argentina. A registered Argentine PSAV may participate in the digital placement, trading and custody of eligible securities, but it must register in all PSAV categories and comply with a second regulatory layer derived from the capital-markets regime. A foreign technology provider may participate without PSAV registration only when its activity remains limited to the technological generation or maintenance of the digital representation and does not independently fall within the statutory PSAV perimeter. (CNV Rules, Title XXII, Chapter I, Sections 11, 14, 19, 23 and 30.)

The regime should therefore be treated as an extension of regulated securities infrastructure, rather than as a general authorization to issue or trade tokenized assets. A company considering this route must analyze the issuer, the underlying security, the public-offering authorization, the registered holder, the ADCVN deposit, the participating PSAVs, the technology provider, the custody model and the allocation of responsibility as parts of one transaction structure.

Frequently Asked Questions

Is There a Crypto License in Argentina?

Argentina does not issue an authorization formally called a "crypto license." The applicable authorization is registration as a Proveedor de Servicios de Activos Virtuales, or PSAV, with the CNV. The word "registration" can be misleading because the process involves a substantive review of the applicant's corporate structure, financial position, systems, custody arrangements and compliance framework. (Law No. 27,739, Sections 37 to 39; CNV General Resolution No. 1058/2025, Sections 1 and 6.)

What Is a PSAV in Argentina?

A PSAV is a person or company that performs specified virtual-asset services as a business for, or on behalf of, another person. The five covered activities are fiat-to-crypto exchange, crypto-to-crypto exchange, virtual-asset transfers, custody or administration, and financial services related to an issuer's offer or sale of a virtual asset. The Argentine concept is functionally equivalent to the international term VASP. (Law No. 25,246, Section 4 bis.)

Who Regulates Crypto Companies in Argentina?

The CNV administers the PSAV registry and supervises registered providers' financial, operational, custody, cybersecurity and conduct obligations. The UIF separately regulates their AML, counter-terrorist-financing and counter-proliferation-financing duties. Other authorities may become relevant when the product includes fiat payment services, securities, lending, foreign exchange transactions, consumer contracts or personal-data processing. (Law No. 27,739, Sections 37 and 38; Law No. 25,246, Section 20(13); UIF Resolution No. 49/2024.)

Which Crypto Activities Require PSAV Registration?

Registration may be required for: (a) exchanging virtual assets and fiat currency; (b) exchanging one virtual asset for another; (c) transferring virtual assets for customers; (d) holding or administering virtual assets or instruments that control them; or (e) providing financial services connected with an issuer's offer or sale. A product performing several functions must register in every corresponding category. (CNV General Resolution No. 1058/2025, Section 8.)

Can a Foreign Crypto Exchange Serve Argentine Users Without Registering?

A foreign exchange must register when it performs a covered activity and meets any CNV territorial trigger. Those triggers include using a ".ar" domain, integrating local fiat ramps, clearly targeting Argentine residents, directing advertising at them or generating more than 20 percent of its relevant business volume in Argentina. Mere offshore incorporation does not exclude Argentine regulation. (CNV General Resolution No. 1058/2025, Sections 1 and 3.)

Does Reverse Solicitation Exempt a Foreign Crypto Company?

Reverse solicitation is expressly recognized only within the territorial trigger concerning advertising directed at Argentine residents. It does not override the other triggers. A company contacted by an Argentine customer may still need registration if it uses a local ramp, has clear Argentine targeting, uses a ".ar" domain or crosses the 20 percent business-volume threshold. A statement in the terms of service cannot replace evidence of how the customer relationship originated. (CNV General Resolution No. 1058/2025, Section 3(4).)

Can a Foreign Company Register Directly as a PSAV?

A foreign company cannot operate solely through its original offshore form. It must either participate in an Argentine SA or SRL after registering the foreign shareholder under Section 123 of Law No. 19,550, or register a branch, establishment or permanent representation under Section 118. Under the first route, the Argentine company is the PSAV. Under the second, the foreign company operates through its registered Argentine presence. (CNV General Resolution No. 1058/2025, Sections 1 and 6(b).)

Can a PSAV Be Incorporated as a SAS?

No. General Resolution No. 1058/2025 permits a locally incorporated legal-entity applicant to use the form of an SA or SRL. It does not include the simplified joint-stock company, or SAS, among the eligible forms. A foreign group may also use a Section 118 branch or permanent representation. The choice between an SA, SRL and branch affects governance, shareholder requirements and the allocation of liability. (CNV General Resolution No. 1058/2025, Section 6(b).)

Does a Non-Custodial Wallet Need PSAV Registration?

A provider acting exclusively as a self-custody wallet provider is expressly excluded. The exclusion depends on the actual control architecture, not the product's name. Registration may be required if the provider can sign or block transactions, recover credentials, redirect assets, control sufficient parts of an MPC or multisignature arrangement, or otherwise determine how customer assets are used. (CNV General Resolution No. 1058/2025, Sections 1(iv) and 8, Category 4.)

Can a PSAV Register in More Than One Category?

Yes. The categories are cumulative, and an applicant must register for every activity it performs. A centralized exchange may require Categories 1, 2, 3 and 4 when it supports fiat purchases, crypto trading, customer withdrawals and hosted custody. When several categories apply, the provider satisfies the minimum net worth required for the most demanding category rather than adding every category's amount together. (CNV General Resolution No. 1058/2025, Sections 8 and 9.)

How Much Capital Does a PSAV Need in Argentina?

Categories 1, 2 and 4 require minimum net worth equivalent to USD 150,000; Category 3 requires USD 75,000; and Category 5 requires USD 35,000. A 50 percent reduction applies to certain Categories 1 to 4 providers whose preceding twelve-month transaction or custody volume is below USD 2.5 million. The requirement must be maintained throughout registration. (CNV General Resolution No. 1058/2025, Sections 9 and 10.)

How Long Does PSAV Registration Take?

For a foreign company, the complete process generally takes between five and eight months. This includes establishing the Argentine applicant, preparing and legalizing foreign corporate documents, obtaining tax registration, completing the accounting, technology and AML files, filing through TAD and AIF, and responding to CNV observations. The regulations do not establish a guaranteed period for the CNV's decision.

How Much Does PSAV Registration Cost?

Starting the CNV application does not currently carry a government application fee. Registered providers must pay an annual supervision and control fee. For 2026, the fee is ARS 13,360,000 for legal entities and ARS 5,344,000 for individuals. Separate project costs include corporate registration, apostilles or legalizations, public translations, accounting reports, technology reviews, systems audits and compliance personnel.

What AML Obligations Apply to a PSAV?

A PSAV must implement a risk-based AML system, appoint principal and alternate Compliance Officers, identify customers and beneficial owners, classify customer risk, monitor fiat and on-chain activity, comply with the travel rule, report suspicious operations and submit systematic reports. It must also file specified AML information through the CNV's AIF platform. (UIF Resolution No. 49/2024, Sections 3 to 39; CNV General Resolution No. 1139/2026, Title XI, Section I.)

Can a Company Operate While Its PSAV Application Is Pending?

No. Registration must be obtained before the company performs a covered PSAV activity in Argentina. Completing the CNV web form, initiating a TAD file or obtaining access to AIF does not create provisional authorization. Operating while the application is pending may expose the provider to sanctions and blocking measures. The CNV may also examine the prior activity when assessing the accuracy and consistency of the application. (CNV General Resolution No. 1058/2025, Sections 1, 2, 6 and 40.)

What Happens If a Crypto Company Operates Without Registration?

An unregistered provider may face CNV investigation and administrative sanctions. Where the CNV identifies a possible unlawful act, it may ask the competent prosecutor or court to seek immediate blocking of the provider's website, social-media account or other operating channel. Later filing an application does not retroactively authorize earlier activity. A registered provider may also lose its registration if it ceases to satisfy the applicable integrity and solvency conditions. (CNV General Resolution No. 1058/2025, Sections 2 and 40; CNV General Resolution No. 1139/2026, Section 12.)