Crypto Licensing in Argentina: PSAV Registration

Why Operators Look at Argentina

Argentina suits operators with a genuine Argentine market. The country is consistently ranked among the highest crypto-adoption economies in the world, driven by persistent inflation and capital-control pressures that push retail users toward dollar-pegged stablecoins as a savings and settlement tool. That demand is structural rather than speculative, which is what makes a PSAV registration backed by a real Argentine user base a commercial asset rather than a paper credential.

The flip side is regulatory seriousness. The CNV treats PSAVs as supervised participants, with monthly and annual reporting, external system audits and minimum-net-worth tests, closer to a securities-intermediary regime than a light-touch offshore register. Argentina is also not an offshore wrapper: a local entity is unavoidable, and entities domiciled in FATF high-risk jurisdictions cannot register at all. Operators seeking a cheap, tax-driven structure should look elsewhere; Argentina is for operators committed to the local market.

Regulatory Framework

Crypto is legal in Argentina but is not legal tender; only the Argentine peso has legal-tender status. Virtual assets and their service providers are regulated under a layered framework: Law 27,739 (an AML reform), UIF Resolution 49/2024 (the financial-intelligence obligations), and CNV General Resolutions 994/2024 and 1058/2025 (the registry and operating regime). The CNV is the registration and prudential supervisor; the Unidad de Información Financiera (UIF) is the AML financial-intelligence authority.

How the Regime Came Together

Argentina’s crypto rules moved from absence to a full regime in roughly a year, driven by the FATF/GAFILAT mutual evaluation cycle and FATF Recommendation 15. Law 27,739 (14 March 2024) amended AML Law 25,246 to capture PSAVs as obligated subjects; CNV RG 994/2024 created the registry on 25 March 2024 alongside UIF Resolution 49/2024. The substantive regime arrived with CNV General Resolution 1058/2025, published 14 March 2025 and in force 45 days later, adding the five-category structure, dollar-denominated net worth, the local-entity rule, client-asset segregation, cybersecurity governance and external audits; inscription now runs exclusively through the TAD platform. The reach is broad: foreign providers that direct services to Argentine residents through websites, social media or targeted offers are caught, and operating without registration exposes the platform to court-ordered blocking.

PSAV Categories and Activities Covered

CNV General Resolution 1058/2025 organises PSAV registration around five activity categories, each carrying its own minimum net worth and, for some, its own eligibility rule. A provider registers for the categories that match its actual activities and meets the highest applicable net-worth threshold, tracking the FATF Recommendation 15 definition of a VASP closely.

• Category 1, exchange between virtual assets and legal-tender currencies. Fiat on-ramp and off-ramp, centralised order books pairing crypto with pesos or dollars, OTC desks. Minimum net worth USD 150,000.
• Category 2, exchange between one or more forms of virtual assets. Crypto-to-crypto trading, token-pair markets. Minimum net worth USD 150,000.
• Category 3, transfer of virtual assets. Wallet-to-wallet transfer services, crypto payment processors moving assets between counterparties. Minimum net worth USD 75,000.
• Category 4, custody or administration of virtual assets, or of instruments enabling control of them. Custodial wallets, key-management services, exchange custody arms. Minimum net worth USD 150,000.
• Category 5, participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset. Primary-issuance support, token-sale platforms. Minimum net worth USD 35,000.

The minimum net worth halves where the provider transacts less than USD 2,500,000 over the prior 12 months, and client virtual assets are excluded from it. Human persons are limited to Categories 1 and 2, so any operator offering custody, transfers or issuance-related services must stand up a local company. RG 1058/2025 also requires a prominent risk warning on any virtual asset launched less than 90 days earlier, and bars any offering that would amount to a public offering of securities (valores negociables) without separate CNV authorisation.

Requirements

Argentina’s PSAV requirements are substantive, not nominal, and there is no offshore-only path. The three make-or-break elements are a local S.A. or S.R.L. (S.A.S. excluded, offshore entities barred); the minimum net worth for the highest registered category, with client assets segregated and excluded; and a full AML and cybersecurity programme with a compliance officer on the board. The local-entity and net-worth tests catch more would-be registrants than the AML paperwork.

Argentina PSAV Requirements at a Glance

What the CNV Actually Reviews

The CNV regime is approval-and-supervision based, not a passive register: it reviews the substance of the documentation rather than rubber-stamping the filing. The binding AML regime is UIF Resolution 49/2024, which requires a risk-based system covering KYC, beneficial-ownership identification, sanctions screening, ongoing monitoring and suspicious-transaction reporting, with Travel Rule logic mirroring FATF Recommendation 16. The common, costly mistake is treating a generic AML policy ported from another jurisdiction as Argentina-compliant. The UIF expects policies calibrated to Resolution 49/2024 and to the operator’s actual model; templates trigger rework at inscription review and again at banking onboarding.

Registration Process and Timeline

A PSAV set-up runs from pre-incorporation to operational launch over a realistic 3 to 6 months. Incorporating the Argentine S.A. or S.R.L. with the Inspección General de Justicia (IGJ) takes roughly 4 to 10 weeks; assembling the AML, cybersecurity, net-worth and corporate documentation takes 6 to 10 weeks of specialist work; the PSAV inscription is then filed through the TAD platform and reviewed by the CNV. All filings are conducted in Spanish, and foreign documents require certified translation and apostille or legalisation. Incorporation is the predictable part; the slow stages are the documentation set and the CNV review.

The compliance documentation is the most time-intensive component, and generic templates cannot shortcut it. The CNV does not run formal pre-application meetings; the practical route is to work through an Argentine firm experienced in CNV filings that screens the documentation set before the TAD submission, since the CNV treats the AML, cybersecurity and net-worth evidence as substantive rather than formal. Operators routinely underestimate how much of the schedule that documentation consumes, and how much depends on banking access that should be pursued from the start.

Taxation

Argentina taxes crypto under its general tax code rather than a bespoke crypto regime, and there is no territorial 0% structure here. A PSAV is a domestic operating company taxed on its profits at the standard corporate rate; individuals are generally taxed at 15% on crypto gains under the income tax (Impuesto a las Ganancias); and crypto holdings fall within the personal-assets tax (Impuesto sobre los Bienes Personales). Most provinces also levy a turnover tax (Ingresos Brutos) on crypto trading, which is the most operationally significant tax for an active platform.

Crypto Tax Treatment

The practical point is that the headline 15% individual rate understates the total tax footprint of a trading business. Corporate income tax, provincial turnover tax and the personal-assets tax on holders all interact. The Ingresos Brutos turnover tax historically applied to gross transaction value, which was punitive for high-volume, low-margin exchange activity; in 2026 the City of Buenos Aires moved to tax the dealing margin rather than the full transaction amount, but treatment still varies by province. Choosing the operating province is therefore a real structuring decision, not a formality.

Ongoing Compliance

A registered Argentine PSAV carries a continuous, supervised compliance load, not a file-and-forget registration. The standing obligations are the board-level compliance officer and public-relations officer, the annual external system audit, the monthly CNV reporting, corporate income tax and audited financial statements, the UIF AML programme, and the locked minimum net worth, which is re-tested against transaction volume. The CNV also funds itself through an annual oversight charge on registered providers.

Periodic Obligations

• Monthly transaction report to the CNV: transaction volume and client count.
• Annual external system audit by certified IT professionals after the fiscal year-end.
• Annual compliance-officer report after the fiscal year-end.
• Audited financial statements filed with the CNV.
• AML reporting to the UIF: suspicious-transaction reports and any periodic reporting under UIF Resolution 49/2024.
• Corporate income-tax and personal-assets-tax filings with ARCA, plus provincial Ingresos Brutos returns.

The CNV supervises PSAVs as registered participants, reviewing the AML programme, the cybersecurity controls, the integrity of client-asset segregation and the accuracy of the monthly reporting and audited statements; the UIF can act in parallel on the AML side. The headline enforcement tool is exclusion from the market: a PSAV that operates without registration, or that loses it, can be blocked in Argentina by court order, and registered providers may not deal with unregistered counterparties. For an operator whose value is its Argentine user base, deregistration is existential, which is why the regime functions more like a supervised licence than a light register.

Banking

Argentina’s strict foreign-exchange controls and the peso’s volatility make the banking and settlement layer the hardest part of operating, harder in practice than the registration itself. Access rests on inscription evidence (or a credible application in progress), institutional-grade AML documentation and a clean ownership and director chain. The typical pattern places domestic peso flows with an Argentine credit institution and holds operating treasury in an external multi-currency account or with a licensed EU EMI, while keeping client virtual assets segregated. Onboarding shares KYC documentation with the inscription pack, so it should run in parallel rather than after registration: a registration without working banking is a certificate on the wall.

FATF Status and EU Market Access

Argentina is not on the FATF grey or black list as of June 2026, and is a member of both FATF and GAFILAT. The joint fourth-round mutual evaluation, with an on-site visit in March 2024, was adopted at the October 2024 plenary; FATF concluded that Argentina had strengthened its AML laws and inter-agency coordination and did not place it under increased monitoring, while flagging effectiveness shortcomings. FATF Recommendation 15 on virtual assets was a direct driver of the PSAV framework, so a registered PSAV in a jurisdiction that is off the grey list reads well in correspondent-banking and counterparty diligence.

EU Market Access

An Argentine PSAV has no EU passporting rights, and MiCA contains no third-country equivalence regime. Article 61 permits third-country firms to serve EU clients only where the client initiates contact entirely on its own initiative for the specific service requested, and ESMA interprets this restrictively: any EU-targeted marketing, EU-language website content, geo-targeted advertising, EU app-store availability or use of EU-based influencers voids the exemption. The carve-out is designed for isolated contacts, not systematic market access. Operators that need the EU market are far better served by a CASP authorisation in a member state such as Lithuania, Cyprus or Malta, which we obtain end to end.

Advantages and Limitations

Argentina offers the deepest crypto-adoption market in Latin America, a now-formalised and FATF-aligned regime and a clear domestic-market footprint, against a demanding net-worth and supervisory load, hard banking and foreign-exchange conditions and no EU passporting. The trade-off is strong for operators committed to the Argentine market and poor for operators looking for a cheap offshore wrapper.

• Latin America’s deepest crypto-adoption market. Structural stablecoin demand from inflation and capital-control pressures makes a real Argentine user base a commercial asset.
• Formalised, FATF-aligned regime. A registered PSAV in a jurisdiction off the FATF grey list reads well in correspondent-banking and counterparty diligence.
• Clear category structure and net-worth scaling. Five defined categories, with the minimum net worth halved below USD 2,500,000 in annual volume, give smaller operators a proportionate entry point.
• Supervised credibility. CNV registration, segregation of client assets and an annual external audit signal a regulated operator to institutional partners.
• × No EU passporting and no third-country equivalence under MiCA. Mitigation: operators targeting EU clients should obtain a separate CASP authorisation in an EU member state, which secures full market access via passporting.
• × Banking and foreign-exchange controls are the practical bottleneck. Mitigation: split domestic peso flows from external multi-currency treasury, pursue banking onboarding in parallel with registration, and reflect client-asset segregation in the account architecture.
• × Demanding net-worth and supervisory load. Mitigation: select the lowest-applicable categories, use the reduced net worth below USD 2.5m annual volume where eligible, and resource the board-level compliance officer and annual audit from the outset.
• × No offshore or cheap-wrapper path; a local entity is unavoidable. Mitigation: operators without a genuine Argentine market are usually better served by an EU CASP regime such as Lithuania, Cyprus or Malta, where we deliver formation and licensing directly.
• × Macro and currency instability. Mitigation: hold treasury in external multi-currency or dollar accounts, and price the provincial turnover-tax exposure into the operating-province decision.

How Argentina Compares

Argentina sits in the Latin American peer group alongside Panama (no operative licence; bills pending), El Salvador (formal DASP authorisation under the Digital Assets law, 0% tax on digital-asset activities for licensees) and Costa Rica (SUGEF VASP AML registration). Cyprus provides the EU cross-tier reference: a MiCA CASP authorisation with full passporting, and one of the jurisdictions where we deliver formation and licensing directly.

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Argentina is the only one of the Latin American group with a fully in-force, supervised PSAV regime that requires real net worth and a local entity. That seriousness is a strength for operators serving the Argentine market and a cost for everyone else. The decisive question is whether the operator’s users are actually in Argentina. If they are, a domestic registration is the right call. If they are not, an EU CASP regime usually gives a stronger combination of market access, banking and credibility.

When Argentina Is the Right Choice

Argentina fits if:

• Your users are genuinely Argentine residents and the local market is your core market.
• You want a supervised, FATF-aligned registration rather than a light offshore register.
• You can fund the minimum net worth and resource the ongoing compliance, audit and reporting load.
• You can manage Argentine banking and foreign-exchange controls as a known operating cost.

Look at a jurisdiction we serve directly if:

• You need systematic EU market access through a MiCA CASP authorisation: Lithuania, Cyprus or Malta.
• You want a credible non-EU base with an established regime: Gibraltar or Switzerland.
• You want one accountable firm to form the company, file the application and deal with the regulator. In those jurisdictions, that is exactly what we do.

Frequently Asked Questions

Banking & Payments

A company and a licence still need a bank account

Banking is one of our three core services. We help high-risk and regulated businesses open the bank and payment accounts that others refuse: we work directly with EU EMIs, payment institutions and crypto-aware banks, confirm appetite before you apply, and make the introduction. Take it with your company and licence, or on its own.

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Where We Deliver Crypto Licensing

• Lithuania Crypto Licensing: a MiCA CASP authorisation with full EU passporting
• Cyprus Crypto Licensing: CySEC-supervised MiCA CASP route into the EU
• Malta Crypto Licensing: an established EU regime under MiCA
• Crypto Licensing Overview: the full set of jurisdictions we serve
• Company Formation: the entity layer, formed and filed by us