Crypto License in Argentina
Securing Your VASP Registration in Argentina
The Republic of Argentina, with its high rate of cryptocurrency adoption driven by macroeconomic factors, has rapidly transitioned from a largely unregulated market to a mandatory compliance jurisdiction for Virtual Asset Service Providers (VASPs). The core of this regulatory revolution is Law N°27,739 (2024), which decisively appointed the National Securities Commission (Comisión Nacional de Valores, CNV) as the chief regulator for the crypto industry, establishing a mandatory VASP Registry. This crucial legislative development moves Argentina into alignment with the global Financial Action Task Force (FATF) standards, making it impossible for crypto businesses to operate legally without proper registration and stringent adherence to Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) protocols.
This comprehensive guide, designed for legal professionals, fintech founders, and compliance officers, provides an exhaustive analysis of the Argentina Crypto License (which is formally a mandatory registration), detailing the corporate, financial, technical, and reporting requirements. We will analyze the pivotal roles of the CNV and the Financial Information Unit (UIF), dissect the stringent Minimum Net Worth requirements, and outline the exact roadmap for achieving successful VASP registration in Argentina. Understanding this mandatory registration framework is the single most critical factor for any domestic or foreign entity wishing to legally access Argentina’s rapidly expanding crypto market. The new regime is designed to ensure consumer protection, financial integrity, and systemic stability, marking a clear end to the regulatory “grey zone.”
The Legal Foundation: CNV Mandate and VASP Definition
The regulatory shift in Argentina is not merely a technical update but a systemic legal restructuring of the country’s financial landscape, driven by international pressure and the need for fiscal transparency.
Key Legislation and Regulatory Authorities
The regulatory environment for virtual assets is defined by two primary legislative bodies and their respective resolutions:
Law N°27,739 (2024): This core law reformed Argentina’s AML/CTF framework, explicitly defining Virtual Assets and Virtual Asset Service Providers (VASPs) and mandating their inclusion as reporting entities.
National Securities Commission (CNV): Appointed as the primary regulatory and enforcement authority for VASPs. The CNV established the Registry of Virtual Asset Service Providers via General Resolution 994/2024.
Financial Information Unit (UIF): Argentina’s Financial Intelligence Unit (FIU) remains the supreme authority for AML/CTF. VASPs must not only register with the CNV but are also mandated by the UIF (Resolution 49/2024) to act as reporting entities, with strict obligations for Suspicious Activity Report (SAR) filing and enhanced Customer Due Diligence (CDD).
The Argentine VASP regulatory framework is a dual-authority structure, requiring compliance with the CNV for registration and licensing oversight, and the UIF for all ongoing AML/CTF reporting duties.
Defining the Obligation: Who Must Register?
The definition of a VASP under Argentine law is broad and fully aligned with FATF standards, making the Argentina VASP registration mandatory for any entity carrying out commercial activities involving virtual assets.
The obligation applies to:
Argentine Entities: All legal entities (S.A. or S.R.L.) incorporated in Argentina that provide VASP services.
Foreign Entities: Non-resident companies are required to register if they target Argentine residents through:
The use of “.ar” domain names for operations.
Commercial agreements with local third parties to receive funds or assets from Argentine residents.
Directing advertising, marketing, or commercial efforts specifically toward the Argentine market.
Threshold Exemption (Low-Frequency Keyword): An important exception exists: VASPs are exempt from mandatory registration if their aggregate monthly transaction volume does not exceed 35,000 UVAs (Units of Purchasing Power, equivalent to approximately USD 30,000 as of 2025). This threshold is vital for small-scale operators.
VASP Defined Activities (Mandatory Registration Applies):
Exchanging virtual assets for legal tender (fiat currency).
Exchanging one or more forms of virtual assets (crypto-to-crypto trading).
Transferring virtual assets (remittance or payment processing).
Custody and/or administration of virtual assets or instruments enabling control over them (hosted wallets, key management).
Providing financial services related to an issuer’s offering or sale of a virtual asset.
The VASP Registration Roadmap: Corporate and Capital Requirements
The VASP registration Argentina process is structured and rigorous, demanding significant upfront investment in corporate structure and audited capital.
2.1. Corporate Establishment and Structure
The applicant must first establish a legal presence in Argentina.
Legal Form: The most common and recommended corporate vehicles are the Sociedad Anónima (S.A.) or the Sociedad de Responsabilidad Limitada (S.R.L.). The Articles of Association must explicitly state the intention to carry out VASP activities as outlined in Law N°27,739.
Management: The company must appoint at least one Director. Crucially, while a local Argentine director is not strictly mandatory, a designated Legal Representative must be appointed for official communication and representation before the CNV and the UIF.
Compliance Personnel: The appointment of a qualified Compliance Officer (CO) and an Alternate Compliance Officer is mandatory. The CO must be registered with the UIF and possess verifiable experience in AML/KYC standards specific to virtual assets.
Office Requirement (Low-Frequency Keyword): A physical or virtual office in Argentina is required to secure a local address and prove corporate domicile, a basic requirement for tax and regulatory purposes.
Minimum Net Worth (MNW) and Financial Stability
The most significant financial barrier to entry is the mandatory Minimum Net Worth (MNW) requirement, which varies based on the VASP’s specific activities. This ensures the company has sufficient financial backing to absorb potential operational risks and protect client assets.
| VASP Activity Category | Minimum Net Worth (MNW) Requirement | Purpose |
| I. Exchange & Custody (High Risk) | USD 150,000 – 170,000 (Net Worth) | Required for firms dealing with high-volume trading and asset safekeeping (e.g., major exchanges). |
| II. Transfer Services (Medium Risk) | USD 75,000 – 85,000 (Net Worth) | Required for companies focusing primarily on crypto remittances and payment processing. |
| III. Basic Services (Low Risk) | USD 35,000 (Net Worth) | Required for other defined VASP activities not falling into the higher risk categories. |
Note: The MNW must be certified by an independent Argentine Certified Public Accountant (CPA) based on recent financial statements, no older than eight months.
The VASP Registration Application Dossier
The application submitted to the CNV must be comprehensive, demonstrating full compliance and operational readiness.
| Required Component | CNV/UIF Compliance Focus |
| I. Corporate and Legal Documents | Articles of Incorporation, proof of registered local office, identification (ID/Passport) and non-criminal record certificates for all directors/shareholders. |
| II. Financial Documentation | CPA-certified Minimum Net Worth statement, detailed financial projections (3 years), and proof of initial contributed capital. |
| III. AML/CTF Compliance Program | Comprehensive Risk-Based Approach (RBA) manual, internal control systems, detailed KYC/CDD/EDD procedures, and the Suspicious Activity Reporting protocol aligned with UIF Resolution 49/2024. |
| IV. Technology and Security | Description of the IT infrastructure, cybersecurity policies, asset custody procedures, and data protection/privacy policy. |
| V. Business Plan | Detailed description of the business model, target market, expected transaction volume, and risk mitigation strategies. |
AML/CTF Compliance: The Central Role of the UIF
While the CNV grants the operational authority, the Financial Information Unit (UIF) dictates the ongoing responsibilities of the VASP as a reporting entity. Adherence to UIF mandates is paramount for avoiding severe penalties and maintaining legal status.
UIF Registration and Reporting Obligations
Upon CNV registration, the VASP must concurrently register with the UIF. This triggers several key compliance obligations:
Mandatory Reporting Thresholds: VASPs must report any transaction involving virtual assets that equals or exceeds six times the minimum monthly wage (or approximately USD 1,350), or any transaction deemed suspicious, regardless of the amount.
Detailed Client Information: VASPs must submit detailed reports to the UIF regarding account holders, including their personal information and all necessary Know-Your-Customer (KYC) documentation, ensuring full traceability.
Risk-Based Approach (RBA) Application: The VASP must implement an RBA that categorizes clients and transactions based on risk. This requires:
Enhanced Due Diligence (EDD): For high-risk clients (e.g., Politically Exposed Persons (PEPs), clients from high-risk jurisdictions, or those with complex ownership structures), the VASP must collect additional information, including the verifiable Source of Funds (SoF) and Source of Wealth (SoW).
Ongoing Monitoring: Continuous screening of client transactions and counterparties against global sanctions lists (e.g., OFAC, UN) and internal “red flag” indicators.
Travel Rule Implementation
Argentina’s commitment to FATF standards includes the mandatory adoption of the Travel Rule (FATF Recommendation 16). This requires the VASP to share specific originator and beneficiary information during cross-border transfers of virtual assets.
Information to be Collected: The originator VASP must collect and hold the originator’s name, wallet address, and physical address or national ID number, and similar information for the beneficiary.
Technical Solution: The VASP must employ a technical solution (e.g., a TRISA-aligned protocol or similar secure messaging system) to transmit this data securely and immediately to the beneficiary VASP during the transfer of virtual assets. This technical capability must be auditable.
VASP-to-Unhosted Wallet: Transfers to unhosted (self-custody) wallets still require the originating VASP to gather reasonable information about the counterparty, performing a risk assessment based on the purpose and amount of the transaction.
AML Audit and Internal Controls
The VASP must establish rigorous internal control systems, which are subject to regulatory inspection.
| Internal Control Component | UIF/CNV Standard Requirement |
| Compliance Officer (CO) Role | Dedicated, independent, and possessing direct reporting line to the highest management level. Responsible for ongoing monitoring, training, and SAR filing. |
| Internal Audit Program | Mandatory annual internal review of the entire AML/CTF framework to test the effectiveness of KYC/CDD procedures and transaction monitoring systems. |
| Record Keeping | All client records (KYC, CDD, transaction history) must be maintained for a minimum of 10 years in an accessible, secure, and easily retrievable format. |
| Training Program | Mandatory, documented, and recurrent training for all staff on AML/CTF policies, changes in regulations, and identification of suspicious activities. |
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Technical and Operational Requirements: Cybersecurity and Custody
The CNV’s oversight is not limited to compliance but extends deeply into the VASP’s operational security and technological resilience. High standards of cybersecurity and data protection are integral components of securing and maintaining the Crypto License in Argentina.
Security and Disaster Recovery
VASPs must demonstrate a robust defense-in-depth security strategy.
IT Infrastructure Audits: The VASP must undergo independent Penetration Tests (Pen Tests) and security audits on its core trading engine, custody system, and client-facing interfaces.
Business Continuity and Disaster Recovery (BCP/DR): Mandatory documentation and annual testing of BCP and DR plans to ensure continuous service provision and rapid recovery of client funds in the event of a catastrophic failure or cyberattack. The Recovery Time Objective (RTO) and Recovery Point Objective (RPO) must be formally defined and validated.
Data Protection: Compliance with Argentina’s Personal Data Protection Law (Law N° 25.326) is crucial. Client data must be encrypted, access must be strictly controlled (least privilege access), and data storage must meet regulatory domicile requirements.
Custody and Key Management Protocols
For VASPs providing crypto custody services, the requirements are particularly demanding to mitigate systemic risk.
Cold Storage Mandate (Low-Frequency Keyword): Custody providers must employ a tiered storage strategy, with the vast majority of client assets (typically over 95%) held in air-gapped cold storage utilizing Hardware Security Modules (HSMs).
Key Generation and Ceremony: The process for private key generation, storage, and multi-signature access (e.g., Multi-Party Computation (MPC) protocols) must be formally documented, with a detailed, auditable key ceremony process to prevent single points of failure.
Segregation of Assets: Client assets must be strictly segregated from the VASP’s proprietary assets at all times. This separation must be verifiable on-chain and through internal accounting, providing full proof of reserve.
Tax Compliance and Fiscal Reporting: AFIP’s Oversight
While the CNV focuses on securities and AML, the Federal Administration of Public Revenues (AFIP) enforces tax compliance, which is a major concern in the Argentine market.
Tax Status of Virtual Assets
The tax classification of virtual assets is complex and depends heavily on the activity:
Income Tax (Impuesto a las Ganancias):
Occasional Trading: Gains from occasional crypto sales are generally subject to capital gains tax (15% for non-residents and residents).
Commercial Activity: For a registered VASP, profits from core trading and fee activities are typically classified as business income, subject to the corporate income tax rate (25% to 35%, depending on the volume and legal form).
Value Added Tax (VAT / IVA): Crypto-to-crypto exchange services are generally exempt from VAT. However, fees for other services, such as custody or payment processing, may be subject to VAT if the service is deemed to be performed in Argentina.
Wealth Tax (Impuesto sobre los Bienes Personales): Argentine residents must declare their crypto holdings (including those held abroad) for Wealth Tax purposes, adding complexity for the VASP’s reporting duties toward its clients.
AFIP Reporting and Information Regimes
AFIP imposes specific information reporting regimes on registered VASPs to ensure fiscal transparency and combat tax evasion, making the AFIP CNV reporting interconnected.
Mandatory Monthly Reporting: VASPs are required to submit monthly reports to AFIP detailing client holdings, transaction volumes, and trading activities that exceed specified thresholds.
Tax Residency Verification: The VASP must implement processes to accurately verify the tax residency of all clients to correctly apply withholding taxes and comply with international exchange of information agreements (e.g., CRS – Common Reporting Standard).
Tax Amnesty and Regularization
Argentina frequently introduces Special Voluntary Asset Disclosure Regimes (tax amnesty programs). VASPs are often instrumental in these programs, as they hold the verifiable data needed for clients to declare previously undeclared holdings, including cryptocurrencies, under favorable tax rates. This regulatory interaction requires the VASP’s compliance and tax teams to work closely, positioning the VASP as a key facilitator of fiscal regularization.
Regulatory Roadmap and Deadlines
The transition period for mandatory VASP registration Argentina set forth by the CNV is critical, with different deadlines applying to various entities.
Mandatory Registration Deadlines
The initial deadlines for VASP registration are tight and reflect the urgent push for FATF compliance:
| Entity Type | Original Registration Deadline | Compliance Status |
| Individuals (Natural Persons) | July 1, 2025 | CRITICAL. Operations must cease until registration is complete. |
| Argentine Legal Entities (S.A./S.R.L.) | August 1, 2025 | CRITICAL. Operations must cease until registration is complete. |
| Foreign Legal Entities | September 1, 2025 | CRITICAL. Operations must cease until registration is complete. |
Any VASP that failed to meet these deadlines must immediately cease all operations in Argentina and can only resume activities after the CNV grants final registration.
CNV VASP Approval Process Steps
The CNV review process is thorough and typically takes 60 to 90 days after the full submission of the dossier.
Pre-Submission & Incorporation: Register the local entity (S.A./S.R.L.), appoint the Compliance Officer (CO), and secure CPA certification for the Minimum Net Worth (MNW).
Application Filing: Submit the complete VASP Dossier (Section 2.3) and all supporting documents (AML Manual, Security Protocols) to the CNV VASP Registry.
Regulatory Review: CNV and UIF simultaneous review. Regulators review the financial stability, governance structure, and the adequacy of the AML/CTF framework based on the proposed RBA.
Requests for Information (RFI): Regulators often issue multiple Requests for Information (RFIs) seeking clarification on technology, key management, or the source of funds for the initial capital. Prompt and detailed response is key to avoiding delays.
Final Approval: Upon satisfactory completion of all reviews, the CNV grants registration and officially lists the VASP in the Public Registry.
Ongoing Compliance: Immediate activation of monthly CNV/AFIP reporting and full UIF AML/CTF compliance (SAR filing).
Strategic Considerations for Foreign VASPs
Foreign entities face unique challenges when attempting to enter the Argentine market, primarily revolving around local representation, capital repatriation, and the exchange control regime.
Local Substance and Legal Representation
Mandatory Local Legal Representative: While a local director is not mandatory, the foreign VASP must appoint a Local Legal Representative who can be held responsible for all legal and regulatory correspondence and potential liability within Argentina.
Foreign Branch Registration: Foreign VASPs can choose to operate through a local Argentine subsidiary or a legally registered branch. Registration as a branch requires additional documentation with the General Superintendency of Corporations (IGJ) but may offer operational continuity with the parent company.
Banking and Repatriation Challenges
The VASP must navigate Argentina’s complex and often volatile banking and foreign exchange environment.
Bank Account Opening: Securing a corporate bank account in Argentina for crypto-related activities is highly challenging due to banks’ extreme risk aversion toward the sector. The VASP must present a flawless, audited AML/CTF program and demonstrate the separation of client and proprietary funds.
Capital Controls: Argentina frequently imposes strict capital controls on the repatriation of profits and the conversion of local fiat (Argentine Peso) to foreign currency. Foreign VASPs must structure their revenue flows to minimize reliance on local fiat conversions for profit extraction, prioritizing crypto-to-crypto or stablecoin operations.
VASP Operating Checklist: Post-Registration Focus
| Focus Area | Key Performance Indicator (KPI) | Frequency |
| AML/UIF | SAR Filings (Timeliness and quality of reports) | Continuous / As needed |
| CNV Governance | Minimum Net Worth (MNW) maintenance (Quarterly Balance Sheet review) | Quarterly |
| Technology | Penetration Test Remediation (Completion of all High-Severity fixes) | Annual |
| Tax/AFIP | Client Holdings Reporting (Accuracy of client data submitted to AFIP) | Monthly |
| Training | Compliance Training Log (100% employee participation documented) | Annual |
Consumer Protection and Market Integrity: The CNV’s Mandate
Beyond AML/CTF compliance, the CNV imposes specific regulations to ensure market integrity, protect the Argentine investor base, and foster transparency—requirements that are increasingly becoming a benchmark for global Crypto License jurisdictions.
Transparency and Conduct Obligations
Registered VASPs are held to high fiduciary and ethical standards, similar to traditional financial entities under CNV oversight.
Code of Conduct: VASPs must develop and make publicly available a comprehensive Code of Conduct. This code must clearly outline the VASP’s commitment to fair treatment of clients, principles for managing conflicts of interest, and strict customer protection standards.
Information Provision: Crucially, VASPs must ensure that all information provided to clients—including marketing, risk disclosures, and terms of service—is clear, truthful, and not misleading. The CNV strictly prohibits any promotion that minimizes the inherent risks associated with virtual asset trading or custody, demanding full transparency on volatility and potential loss.
Complaint Management: A formal and efficient Customer Service and Complaint Management Mechanism is mandatory. This mechanism must be adequately staffed and capable of addressing client issues promptly, with documented procedures for escalation and resolution.
Governance and Reporting Focus
The CNV utilizes periodic reporting to monitor operational risk, solvency, and market activity, ensuring that the Minimum Net Worth remains adequate over time.
Quarterly Reporting: Registered VASPs must submit quarterly reports to the CNV detailing:
The total number of active clients and accounts.
The volume of virtual assets traded (broken down by asset type).
Financial metrics to demonstrate ongoing compliance with the MNW requirements.
Annual IT Systems Audit (Low-Frequency Keyword): In addition to the AML Audit, an annual audit of the VASP’s entire IT system is required. This audit, conducted by an independent and qualified professional, must cover system operations, security protocols, data integrity, and, critically, provide proof of reserves to guarantee that client assets are held as stated.
The Regulatory Frontier: Tokenization, DeFi, and the Sandbox
Argentina is not only regulating the past (exchanges) but is actively embracing the future of finance through progressive tokenization laws and regulatory sandboxes, positioning the registered VASP as a key intermediary in this new ecosystem.
Tokenization of Real-World Assets (RWA)
The CNV has introduced a pioneering framework for the tokenization of real-world assets (RWA) under General Resolution 1069/2025. This makes Argentina a regional leader in bridging traditional finance and blockchain technology.
Scope: The initial scope of the resolution applies to the tokenization of publicly offered financial instruments, such as debt securities or participation certificates of publicly traded financial trusts.
VASP Role: Registered Virtual Asset Service Providers (VASPs) are exclusively authorized to:
Commercialize and manage these digital representations.
Provide custody for the tokenized securities, ensuring asset segregation and investor protection.
Functional Equivalence: A core principle is functional equivalence. Investors must retain the right to convert their tokenized holdings back into traditional, non-digital format at any time, guaranteeing the underlying economic rights. This integration means that the Argentina Crypto License is essential for operating in the regulated digital securities market.
The Regulatory Sandbox
To test the RWA tokenization framework, the CNV implemented a one-year regulatory sandbox.
Purpose: The sandbox functions as a controlled test environment to evaluate the operational impact, systemic risks, and legal implications of the new tokenization schemes without immediate, full-scale deployment.
Benefits for VASPs: Participation in the sandbox allows registered VASPs to pilot innovative tokenization products under close regulatory supervision, gaining a significant first-mover advantage and direct input into the final, permanent regulation.
DeFi and Unregulated Zones: While the CNV focuses on centralized and tokenized finance, Decentralized Finance (DeFi) protocols operating without an identifiable centralized intermediary currently remain largely outside the direct regulatory scope. However, any centralized entity (the VASP) that interacts with DeFi protocols must incorporate that activity into its AML Risk-Based Approach (RBA), often applying extreme Enhanced Due Diligence (EDD) on funds originating from or moving to such platforms.
Final Roadmap Synthesis: Strategic Integration
Achieving a sustainable VASP registration in Argentina demands a highly integrated strategy that satisfies all three major regulatory bodies (CNV, UIF, and AFIP) simultaneously.
Cross-Regulatory Compliance Requirements
The following schema illustrates the overlapping nature of the VASP’s mandatory obligations:
| Regulatory Body | Core Function | Primary Mandate on VASP |
| CNV (Securities Regulator) | VASP Registration & Oversight | Minimum Net Worth, Corporate Governance, Consumer Protection, IT System Audit, Tokenization Framework. |
| UIF (Financial Intelligence Unit) | AML/CTF Enforcement | Risk-Based Approach (RBA), Suspicious Activity Reporting (SAR), FATF Travel Rule Implementation, Ongoing Monitoring. |
| AFIP (Tax Authority) | Fiscal Compliance | Monthly Client Reporting, Tax Residency Verification, Compliance with Income Tax and Wealth Tax obligations. |
The Value Proposition of Compliance
The strict compliance regime ultimately delivers a powerful commercial advantage:
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Regulatory Certainty: The legal clarity provided by Law N°27,739 removes the regulatory risk that plagued the market previously, making Argentina a safe and predictable environment for investment.
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Banking Access (High-Frequency Keyword): While challenging, a fully compliant, CNV-registered VASP with certified MNW and robust UIF reporting stands a significantly better chance of securing local and international banking services than an unregulated entity.
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Investor Trust: Operating with an official Argentina Crypto License (VASP registration) drastically enhances client confidence and facilitates partnerships with traditional financial institutions.
The Argentine VASP registration is the necessary cost of admission to a highly motivated and growing crypto user base, providing not only legal status but a seal of regulatory approval.
FAQ
No. Argentina does not issue a specific prudential "crypto license." The legal requirement is mandatory registration and compliance as a Virtual Asset Service Provider (VASP) under existing AML/CTF laws.
The primary body is the Unidad de Información Financiera (UIF), Argentina’s Financial Information Unit. The UIF classifies VASPs as "obligated subjects" under the AML framework.
UIF Resolution 300/2024 (or subsequent updates) establishes the mandatory Argentina VASP registration process and details the specific AML compliance Argentina crypto duties, including the Risk-Based Approach and reporting.
The BCRA does not regulate VASP activities directly but maintains a cautious stance, issuing warnings and imposing foreign exchange (FX) restrictions on local financial institutions dealing with virtual assets.
Yes. Any foreign entity targeting Argentine residents or operating within the country must establish a local legal entity and complete the mandatory Argentina VASP registration.
Establishing a comprehensive, documented, and continuously updated Risk-Based Approach (RBA) to identify, assess, and mitigate money laundering and terrorist financing risks specific to the VASP’s operations.
Yes. A qualified and locally based Compliance Officer must be appointed. This individual is statutorily responsible for implementing the AML program and liaising directly with the Financial Information Unit Argentina.
VASP profits (fees/commissions) are subject to corporate income tax. Businesses also need to comply with provincial turnover tax (Ingresos Brutos) and other national levies, requiring specialized tax advice.
Yes. The Compliance Officer must immediately file a SAR with the UIF upon forming any suspicion of funds being linked to illicit activity, as mandated by the AML framework.