A PSAV is a virtual asset service provider. In practical terms, it is the individual or legal entity that performs certain activities involving virtual assets, such as exchange, transfer, custody or financial services connected to their offer or sale.

The local PSAV category plays a role similar to the international notion of a VASP. In Argentina, the regime was formally introduced by Law No. 27,739, which amended Law No. 25,246 and brought virtual asset service providers into the anti-money laundering framework as regulated subjects. The National Securities Commission (CNV) was placed in charge of the PSAV registry.

For a crypto, fintech or financial infrastructure company, the central question is concrete: if it performs any of the covered activities, it must assess whether registration with the CNV applies, followed by regulatory and AML obligations before the UIF. For the broader sector framework, see our guide on Fintech Regulation in Argentina.

Legal definition and origin of the PSAV

Law No. 27,739 amended Law No. 25,246 and made PSAVs regulated subjects. It also assigned the CNV the task of keeping the registry that applies to these operators.

The legal definition is built on activities. A company can fall within the regime even if it describes itself commercially as an exchange, wallet, crypto platform, custody provider, virtual asset payment infrastructure or technology provider connected to a token offering. The commercial label is not what decides the question. What matters is the activity actually performed.

Along those lines, PSAV is Argentina's regulatory translation of a category that other markets usually identify as VASP. The purpose of the regime is to place within a supervised framework those who provide relevant services over virtual assets, especially where there is interaction with users, custody, transfers, exchange or participation in offerings connected to virtual assets.

The CNV issued General Resolution No. 994/2024, which created the PSAV Registry. It then issued General Resolution No. 1058/2024, which regulated the applicable regime, including requirements by category, capital demands, cybersecurity and custody.

Who must register as a PSAV

Any individual or legal entity that performs any of the activities covered by the legal definition must assess registration. The rule does not require performing all of them. A single covered activity can be enough to fall within the regime.

The activities that define a PSAV are:

  • Exchange between virtual assets and fiat currency.
  • Exchange between one or more forms of virtual assets.
  • Transfer of virtual assets.
  • Custody or administration of virtual assets or of instruments that provide control over them.
  • Participation in and provision of financial services related to the offer or sale of a virtual asset.

In practice, this definition can reach exchanges, trading platforms, custodians, certain wallet models, virtual asset transfer services and operators with a financial role in the offer or sale of virtual assets.

The analysis must look at the full operating model. What matters includes who owns the user relationship, control or custody over assets, involvement in transfers, the role played in the offer or sale of virtual assets, and how the platform addresses the Argentine market. In projects that combine crypto, payments, lending, financial infrastructure or tokenization, the PSAV question should be reviewed together with the other applicable fintech rules.

How CNV registration works and what it requires

Registration takes place before the CNV, in the PSAV Registry created by General Resolution No. 994/2024. The regime was then developed by GR 1058/2024, which set out requirements by category and demands tied to the operation.

In general terms, the PSAV registration and virtual assets process requires correctly identifying the activity performed, the applicable category, the corporate structure, internal governance, the people responsible for regulatory compliance, and the operational controls that will support the service.

GR 1058/2024 contemplates requirements connected to PSAV categories, capital, cybersecurity and custody. Adjustment deadlines, minimum amounts and specific thresholds should be checked against the rules and CNV criteria in force when the filing is prepared, because the regime is still evolving.

There is also a CNV supervision fee for PSAVs, under interpretive criterion CRI-100. We covered that point in our note on the CNV supervision fee for PSAVs; its concrete economic impact should be verified case by case.

For companies entering the country with a broader strategy, for example crypto, payments, lending, financial infrastructure or tokenization, PSAV registration should be analyzed within the overall plan for fintech market entry in Argentina.

Obligations once registered

Registration does not exhaust regulatory compliance. A registered PSAV remains subject to ongoing obligations before the CNV and, as a regulated subject, also before the UIF.

From the CNV's perspective, obligations depend on the category and the type of activity performed. The regime under GR 1058/2024 includes demands connected to capital, cybersecurity and custody. Those demands must be built into the platform's operating design, its internal policies and the documentation supporting the service.

From the anti-money laundering perspective, PSAVs must comply with obligations before the UIF. Among them:

  • Registration with the UIF.
  • Appointment of a compliance officer.
  • Know-your-customer policies.
  • Due diligence and beneficial owner verification.
  • Transaction monitoring.
  • Suspicious activity reporting.
  • Recordkeeping.

These obligations land squarely on onboarding, transaction monitoring and document retention, and they show up in contracts, terms and conditions, internal policies and the relationship with technology providers.

Foreign operators and cross-border models

A foreign operator seeking to provide virtual asset services in Argentina can structure through an Argentine company owned by the foreign entity, with the latter registered under Article 123 of the General Companies Law. A branch registered under Article 118 can also be considered.

The choice between a local company and a branch should not be treated as a mere formality. It affects corporate governance, liability, local administration, banking relationships, corporate documentation, regulatory compliance and operational capacity before Argentine users.

Cross-border models aimed at Argentine users require case-by-case analysis. In particular, the elements connecting the operation to Argentina should be reviewed: how users are acquired, language, payment methods, advertising, the platform's availability to local residents and the type of service provided. In some cases the operation may require PSAV registration and local compliance even where the platform or part of the infrastructure sits outside the country.

PSAVs and tokenization

Asset tokenization also connects to the PSAV regime. The CNV built a regulatory sandbox through General Resolutions No. 1069/2025, 1081/2025 and 1087/2025, later expanded by GR 1137/2026. That expansion extended the sandbox through 2027 and is part of the local process of regulatory experimentation with tokenized securities.

Within that scheme, tokenized securities trade through registered PSAVs. This makes the registration analysis relevant for traditional crypto exchanges and also for projects seeking to operate infrastructure tied to the tokenization, distribution or trading of tokenized securities.

For more on this point, see our note on the expansion of the tokenization regime (GR 1137).

Frequently asked questions

What is a PSAV?

A PSAV is a virtual asset service provider. The category covers those who perform certain activities over virtual assets, such as exchange, transfer, custody or financial services connected to their offer or sale.

Who must register as a PSAV?

Anyone performing any of the activities covered by the law must assess registration: exchange with fiat currency, exchange between virtual assets, transfers, custody or administration, or financial services related to the offer or sale of virtual assets.

Does a foreign exchange need to register?

It may, if its model targets Argentine users or performs activities covered by the local regime. Foreign operators can structure through an Argentine company under Article 123 or a branch under Article 118, depending on the case.

What happens if I operate without registration?

Operating without registration can create regulatory exposure before the CNV and affect the ability to provide services in the Argentine market. It can also create compliance problems with the UIF, banks, providers, business partners and users.