Argentina PSAV registration (CNV): the technical requirements for a crypto exchange
Argentina has no crypto exchange licence; firms register as PSAV at the CNV under Law 27,739. Capital by category, custody, audits, UIF rules, 2026 changes.
Kostiantyn Boiko, Blockchain Engineer
Argentina does not issue a crypto exchange licence. It runs a registration regime: a business that exchanges, transfers or holds virtual assets for other people must be entered in the CNV’s Registry of Virtual Asset Service Providers (Registro de Proveedores de Servicios de Activos Virtuales, registro PSAV) before it carries out those activities. Law 27,739, passed by Congress on 14 March 2024, added PSAV to the anti-money-laundering law (Law 25,246) and, in Article 37, gave the Comisión Nacional de Valores (CNV) the registry and the supervision and sanction powers of Article 19 of the Capital Markets Law. The detailed rules sit in Chapter III of Title XIV of the CNV Normas, first written by Resolución General (RG) 1058/2025 and replaced in full by RG 1172/2026, dated 14 October 2026, published 15 October and in force 16 October 2026.
The CNV sets capital, custody, cybersecurity, audit and reporting rules; the Unidad de Información Financiera (UIF) sets the AML rules in Resolución 49/2024. This article maps the obligations we verified to a platform control, the evidence the regulator can ask for and an owner. It is a technical reading, not legal advice. Article numbers refer to Chapter III as replaced by RG 1172/2026 unless we say otherwise.
What are the key dates?
| Date | What happened |
|---|---|
| 14 March 2024 | Law 27,739 passed; published 15 March. Article 4 bis of Law 25,246 defines PSAV |
| 25 March 2024 | CNV RG 994/2024 creates the registry; UIF Resolución 49/2024 published, in force the next day |
| 14 March 2025 | RG 1058/2025 published; new applications suspended until it takes effect |
| 26 May 2025 | RG 1058/2025 in force, according to the CNV’s registration page |
| 1 July, 1 August, 1 September 2025 | Registered natural persons, local companies and foreign companies refile; the CNV cancels those that miss the date (RG 1058, Article 6) |
| 31 December 2025 | All RG 1058 provisions apply to providers registered before it |
| 15 October 2026 | RG 1172/2026 published; in force 16 October |
| 1 November 2026 | Monthly report PSAV_014 applies |
Who must register (registro PSAV)?
Article 4 bis of Law 25,246 defines a PSAV as any person who, as a business, performs for others one or more of: exchange between virtual assets and fiat currency; exchange between virtual assets; transfer of virtual assets; custody or administration of virtual assets or of the instruments that control them; and financial services related to an issuer’s offer or sale of a virtual asset.
Chapter III says who files (Article 1):
- Resident natural persons and Argentine companies, before they start. A natural person registers only above UVA 35,000 per calendar month (unidad de valor adquisitivo, an inflation-indexed unit), proven by an accountant’s certificate, and may only run categories 1 and 2 (Articles 7(a)(10), 9).
- Foreign companies with any “point of contact” in Article 4: a “.ar” domain; agreements with third parties or affiliates to receive funds from Argentine residents locally (on-ramps); clear targeting of residents; advertising aimed at them, except reverse solicitation on the client’s exclusive initiative; or more than 20% of business volume in Argentina. They register through an Argentine company (Article 123 of the Companies Law) or a branch or other permanent representation (Article 118).
- Not covered (Article 2): people trading for themselves; merchants paid in virtual assets; decentralised protocols with no person in sufficient control; providers of self-custody wallet software or hardware only; and the foreign parent of a registered Argentine subsidiary with no direct contractual relationship with Argentine clients.
A person required to register must abstain from the activity until registered (Article 3). For an unregistered provider the CNV may ask the specialised prosecutor or court to block its website URL and its social media usernames (Article 41).
What are the categories and the minimum net worth?
| Category (Article 9) | Activity | Minimum net worth (Article 10) |
|---|---|---|
| 1 | Exchange between virtual assets and fiat | USD 150,000 |
| 2 | Exchange between virtual assets | USD 150,000 |
| 3 | Transfer of virtual assets | USD 75,000 |
| 4 | Custody or administration, except where the user keeps exclusive control | USD 150,000 |
| 5 | Services for an issuer’s offer or sale | USD 35,000 |
For categories 1 to 3 the amount halves when volume traded over the last 12 months is below USD 2.5 million; for category 4, when volume in custody is below that figure. A provider in several categories holds only the highest amount. Share capital must be fully paid in and registered; irrevocable contributions are capitalised before filing, or within six months of acceptance once registered. A branch needs assigned capital in Argentina at least equal to the minimum; a permanent representation that cannot be assigned capital places Argentine assets of that value in a guarantee trust (fideicomiso de garantía). If annual financial statements show a shortfall, the provider files a material-event notice (hecho relevante, HR) and a recovery plan within ten business days (Article 11).
What does the application ask for?
A local applicant is a sociedad anónima (SA) or a sociedad de responsabilidad limitada (SRL) whose corporate purpose names PSAV activity expressly (Article 7(b)); simplified companies (SAS) had to convert in 2025. The institutional website must use a “.ar” domain (7(b)(9)). The file includes criminal records and AML declarations for directors, syndics and local representatives, a regulatory compliance and internal control officer, a client relations officer (responsable de relaciones con el público), the shareholder register, and three technical items: the IT expert report (Article 13), the custody description (Article 16) and third-party agreements (Article 36). Filings go through the AIF (Autopista de la Información Financiera), the CNV’s filing portal. Once registered, the provider shows “Inscripto bajo el N°… en el Registro de PSAV de la CNV (República Argentina)” on its website, app and social media (Article 6) and registers with the UIF within 30 days (Resolución 49/2024, Article 42).
Which technical controls and evidence will the CNV look for (requisitos)?
The first column is the legal requirement, paraphrased, with its citation. The other columns are our implementation recommendation; the rule does not name these roles. “Software” means the control ships with the platform; “Operator” means the licensee or its advisers produce it.
| Requirement (citation) | Control in the platform | Evidence | Owner |
|---|---|---|---|
| Order and transaction records with time to the second, quantities, asset, internal ID or on-chain TXID, client (Art. 12) | Append-only order log; ledger entries linked to TXIDs | Export for a date range | Software |
| Description of IT systems; IT expert report on inalterability, security, backup and contingency, filed via AIF, non-public (Art. 13) | Architecture document; backup and restore procedure | Expert report; timed restore drill | Operator commissions; vendor supplies the architecture |
| Cybersecurity on five functions: governance with periodic assessments and audits; critical systems identified; protection of user data, interconnections and insider threats, with access assignment, review and revocation; real-time detection; response and recovery (Art. 14) | Role-based access with 2FA; off-host logs; monitoring and alerts; segmented trading, custody and user data | Role matrix; access review; alert log; recovery test | Both |
| Board-approved information security policy: key generation, storage, backup, recovery, replacement and secure deletion; wallet categories; key access per role; review after incidents (Art. 15) | Key ceremony procedure; wallet tiering; named key roles | Policy; board minutes | Operator, with vendor input |
| Custody architecture via AIF: own or third-party custody, networks and operating addresses, cold/warm/hot, multisig or MPC; public proof of reserves (Art. 16) | Wallet map; signed proof-of-reserves export | AIF filing; PoR page | Both |
| Client assets segregated in internal records, at other PSAV and on-chain, booked as memorandum accounts (cuentas de orden); dedicated client wallet at any third-party custodian (Art. 17) | Separate client and company wallets; ledger flags; ledger-versus-chain reconciliation | Reconciliation report; wallet list | Software reconciles; operator’s accountants book it |
| Tiers of human verification by transaction threshold plus cold storage, key distribution across isolated sites, multisig with named roles or outgoing whitelists (Art. 18) | Policy engine with M-of-N approvals by amount band; whitelists with delays | Policy configuration; approval log | Software; operator sets thresholds |
| Fiat at a bank authorised by the BCRA (the central bank), a foreign bank with Basel III-equivalent standards or a BCRA-registered payment service provider; no proprietary use of client assets (Arts. 19, 20) | Separate bank accounts | Statements versus ledger | Operator |
| Annual systems audit of functioning, security, continuity, inalterability, backups, proof of reserves and smart contracts, signed by an IT expert with virtual-asset security experience, recorded in board minutes, filed within 70 days of year end (Arts. 21, 40(c)) | Evidence pack: logs, backups, PoR, change history | Audit report; minutes | Operator commissions; both support |
| Auditable electronic ledger with permanent monitoring (Art. 28); records kept at least 10 years, outsourced storage under the provider’s responsibility (Art. 39; UIF Res. 49/2024, Art. 17) | Double-entry ledger; immutable archive | Ledger export; restore test | Both |
| Wallet addresses kept current with the CNV; monthly PSAV_014 within 15 days (clients, USD volume, top 10 assets, custody per asset) as TXT files per Annex I; immediate HR for cyberattacks, outages and custody problems (Art. 40) | Reports generated from the ledger; incident classes | Filed reports; HR log | Software generates; operator files |
| Agreements that integrate operations or delegate PSAV functions notified within 5 days; a foreign counterparty performing PSAV activities must be AML-regulated in a cooperative, FATF-aligned jurisdiction; no liability waiver (Art. 36) | Third-party register: hosting, KYC, custody, liquidity, software | Register; contracts | Operator |
Two rules shape the documents themselves: no filing may expose the security of the assets or link critical custody roles to named people (Article 23), and offering mixers, tumblers or other anonymisation tools is prohibited (Article 25(q)).
What do the UIF rules add?
A PSAV is an obliged subject (sujeto obligado) under item 13 of Article 20 of Law 25,246, as replaced by Law 27,739. Resolución 49/2024 sets:
- Governance. A compliance officer and alternate registered with the UIF (Article 11); a risk self-assessment and risk tolerance statement to the UIF and CNV before 30 April each year; the independent external reviewer’s report within 120 calendar days after that (Articles 5, 6, 19).
- Reports. A suspicious transaction report (reporte de operación sospechosa, ROS) within 24 hours of classifying an operation as suspicious and no more than 90 calendar days after the operation; 24 hours for terrorism or proliferation financing (Article 36(c)). Monthly systematic reports, filed between the 1st and 15th, of virtual asset operations at or above six minimum wages (SMVM) and of new clients; an annual report between 2 January and 15 March (Article 39).
- Records. Ten years for transactions and client due diligence (Article 17).
- Travel Rule. Article 37 requires identification of the originator and beneficiary of covered transfers under the FATF standards “and in the modality the UIF sets for the exchange and validation of that information”. Article 8(j) makes the provider’s manual say when it may refuse to credit or suspend a transfer that lacks that data. The resolution defines blockchain tracing tools (Article 2(n)) and lists red flags such as sequential transfers and attempts to defeat traceability (Article 34(b)).
The resolution states neither the data fields nor a threshold, and the UIF’s resolution list showed no later rule on the point when we checked it on 1 November 2026; whether the FATF de minimis applies by reference is a question for counsel. The CNV may cancel a registration at the UIF’s request for breaches of the UIF reporting regime, including failure to identify beneficial owners (Article 44(c)).
What happened in 2025 and 2026?
Transition and delays. RG 1058/2025 suspended new applications from 14 March 2025 until it took effect and gave registered providers until 1 July, 1 August or 1 September 2025 to refile. It created the monthly report, first due for October 2025, and made everything else enforceable from 31 December 2025. Criterio Interpretativo 95 (April 2025) told foreign entities how to prove net worth; Criterio 96 (July 2025) set the capital rules and the 30 November 2025 deadline. The 2025 supervision fee was deferred twice, finally to 3–7 November 2025 (RG 1086/2025).
The registry shrank. The CNV reported 101 registrations on 27 December 2024: 95 legal entities (75 local, 20 foreign) and 6 natural persons. The spreadsheet exported from the CNV registry on 1 November 2026 lists 81 current entries, all legal entities. Registration numbers in the file are non-consecutive and run up to 174; we found no CNV cancellation count, although RG 1058 required cancellation of providers that did not refile. Twelve entries carry 2026 dates, the latest 22 October 2026. Only 14 of the 81 list custody (category 4), 13 list all five categories and 65 list one.
Enforcement. On 14 July 2025 the CNV preventively suspended Atómico 3 SA after an inspection; Marval described the measure as the first sanction of a PSAV. Bomchil reports that Cocos moved its crypto service into a separate app in 2026 because BCRA rules restrict financial entities from offering crypto operations.
RG 1172/2026. The October 2026 rewrite folded Criterios 95 to 97 into the text, added the Article 2 exclusions, required the audit signer to have virtual-asset security experience, extended the security policy to the key lifecycle and smart contracts, limited referral partners to redirecting a client, expanded the HR list, added the mixer ban and the 30-day client notice before voluntary cancellation, and re-based the monthly report as form PSAV_014 from 1 November 2026, due even with zero activity (form PSAV_015 for a provider that has not started).
What does the regime not spell out?
- Travel Rule format and threshold. Left to the UIF. Build the data capture and a hold before broadcast now, so the platform adapts when the modality arrives; see when the counterparty cannot receive.
- Incident deadlines. Article 40(d) says “immediately” for cyberattacks and outages; there is no hour limit. Set an internal clock and test it.
- Data location. The CNV rules we read do not require servers in Argentina; Article 19 allows foreign banks and Article 36 regulated foreign custodians. Law 27,739, Article 38(b), tells the CNV to regulate information security and personal data protection, and Law 25,326 governs personal data; assess cross-border hosting with counsel.
- Penetration test cadence. Article 14(a) asks for periodic assessments and audits without a frequency; we recommend yearly tests plus tests after major releases, confirmed with your auditor.
What should an applicant do now?
- Pick categories deliberately. Custody triggers Articles 16 to 18; a model where users keep exclusive control falls outside category 4, while exchange and transfer still register.
- Form the entity and capital first. SA or SRL, express PSAV object, paid-in and registered capital, a “.ar” domain.
- Write the key lifecycle policy and the wallet map before the IT expert reviews the system.
- Produce the monthly reports in the Annex I TXT format, register with the UIF within 30 days and calendar 30 April and the reviewer deadline.
Argentina PSAV FAQ
Does Argentina issue a crypto exchange licence?
No. The CNV registers PSAV under Law 27,739. Registration carries capital, custody, cybersecurity, audit and reporting rules, and a person required to register may not operate without it.
What are the CNV requirements (requisitos) for PSAV registration?
An SA, SRL or registered branch with an express PSAV object and a “.ar” website; minimum net worth by category; an IT expert report on the systems; a custody description and proof of reserves for custodians; compliance and client relations officers; AML declarations for directors; then monthly and annual filings through the AIF.
How much capital does a crypto exchange need in Argentina?
USD 150,000 of net worth for fiat exchange, crypto exchange or custody, USD 75,000 for transfers and USD 35,000 for issuer services; categories 1 to 4 halve below USD 2.5 million of 12-month volume. A multi-category provider holds the highest amount only.
Can a foreign exchange serve Argentine users without registering?
Not if it has a “.ar” domain, local collection agreements, clear targeting or advertising aimed at residents, or more than 20% of its volume in Argentina. Within Article 4, reverse solicitation on the client’s own initiative is the only carve-out.
Does Argentina apply the Travel Rule to crypto transfers?
In principle yes: UIF Resolución 49/2024, Article 37, requires originator and beneficiary identification under FATF standards, but the UIF has still to set the exchange modality. Providers define when they refuse or suspend transfers without that data.
How BitPolaris helps
BitPolaris builds exchange, wallet and custody software with nine chains and a 53-screen operations console. The exchange has an audit log, role-based access with 2FA, KYC tiers, Travel Rule data capture with an export for your Travel Rule provider, and ledger reports with the fields the Article 12 order record and the PSAV_014 report ask for; the operator files them. Custody is self-hosted only, so keys stay inside your perimeter: hot, warm and cold tiers, M-of-N approvals by amount band, whitelists with a 24-hour delay on new addresses, ledger-versus-chain reconciliation around the clock and signed proof-of-reserves exports, which become evidence for Articles 15 to 18 depending on your configuration. The interface is available in Spanish. The white-label cloud option for the exchange runs on dedicated EU servers; declare that hosting under Article 13, notify the agreement under Article 36 and check it against data-protection rules. See deployment models and compliance.
The Licence Technical Pack writes the architecture, key management, continuity, AML and Travel Rule sections from the system you run; Argentina is scoped on request. List prices on 1 November 2026, excluding VAT: exchange €24,500 self-hosted or €1,600 a month plus €7,700 setup on cloud; custody from €15,400 self-hosted. Background: what regulators ask for.
We are not a law firm and do not file applications; you and your counsel do. The pack is not an audit and cannot replace the Article 21 systems audit or the UIF external reviewer. Software gives you controls and evidence; compliance depends on the company, its people and how it operates, and installing our software does not make anyone compliant or registered.
Sources
- Ley 27.739, Infoleg, passed 14 March 2024, B.O. 15 March 2024 (read 1 November 2026)
- CNV, Normas (N.T. 2013), Título XIV Capítulo III (PSAV), consolidated text, Infoleg (read 1 November 2026)
- CNV, Resolución General 1172/2026, 14 October 2026, B.O. 15 October 2026 (read 1 November 2026)
- CNV, Resolución General 1058/2025, 12 March 2025, B.O. 14 March 2025 (read 1 November 2026)
- CNV, Resolución General 994/2024, 22 March 2024, B.O. 25 March 2024 (read 1 November 2026)
- CNV, Resolución General 1086/2025, 2025 supervision fee dates (read 1 November 2026)
- UIF, Resolución 49/2024, 22 March 2024, B.O. 25 March 2024; text also at Contadores en Red (read 1 November 2026)
- UIF, list of resolutions (checked 1 November 2026)
- CNV, Registro público de PSAV and its spreadsheet export (downloaded 1 November 2026)
- CNV, Registro de Proveedores de Servicios de Activos Virtuales, procedure page giving 26 May 2025 as the effective date of RG 1058 (read 1 November 2026)
- CNV, Más de 100 PSAVs se inscribieron en el registro creado por la CNV en 2024, 27 December 2024 (read 1 November 2026)
- Ley 25.326 de Protección de los Datos Personales, argentina.gob.ar (read 1 November 2026)
- Marval O’Farrell Mairal: Nueva regulación para PSAV, 18 March 2025; Nuevas normas de ciberseguridad para el sector crypto, 23 April 2025; Novedades para registrar entidades extranjeras como PSAV, 28 April 2025; Nuevo Criterio Interpretativo sobre el régimen PSAV, 17 July 2025; Primera sanción de la CNV a un PSAV, 28 July 2025; Se actualiza el régimen de los PSAV, 26 October 2026 (all read 1 November 2026)
- Bomchil, Boletín Fintech & Economía Digital No. 18, October 2026 (read 1 November 2026)
- Bruchou & Funes de Rioja, La CNV establece nuevo marco regulatorio para PSAV, 14 March 2025 (read 1 November 2026)
- Estudio O’Farrell, La CNV actualiza el régimen aplicable a los PSAV, 15 October 2026 (read 1 November 2026)
- Pérez Alati, Grondona, Benites & Arntsen, La CNV aprueba modificaciones integrales al régimen de PSAV, 27 October 2026 (read 1 November 2026)
- CriptoNoticias, Cambios para usuarios: la CNV revisa el régimen de exchanges, 16 October 2026 (read 1 November 2026)