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Today the Central Bank of the Argentine Republic (“CBAR”) issued Communication “A” 6776 clarifying certain aspects of the new exchange control regime established by Executive Decree No. 609/2019 and Communication “A” 6770 issued by the CBAR.

The main clarifications made are the following:

i. Export of Goods: The maximum repatriation terms for the obligation to repatriate and settle proceeds from exports of goods shall be counted as from the date on which Customs certifies the shipment of the exported goods. Additionally, the maximum settlement term of fifteen (15) calendar days applicable to the export to related companies and of certain goods (mostly commodities) is extended to other products, such as wheat, wicker, lead, concentrates, among others;

ii. Payment obligations in foreign currency between residents: The restriction to access to the foreign exchange market for payments in foreign currency between residents shall not apply to the payments made by customers of local financial entities related to: (i) financing granted in foreign currency; or (ii) credit card consumptions made in foreign currency;

iii. Payment of imports of services to related companies: The restriction to access to the foreign exchange market for the payment of imports of services to related companies shall not apply to: (i) local agents that collect payments made by residents to non-residents for services provided (payment processors); and (ii) local financial entities for the expenses paid to foreign financial entities regarding their usual operations;

iv. Swap and arbitration transactions: The restrictions applicable to swap and arbitration transactions shall not apply to the repatriation of foreign currency for transactions that do not have the obligation to be settled in the foreign exchange market;

v. Transfers of funds abroad by individuals: It is clarified that there is no restriction for the transfer of foreign currency by individuals from their local bank accounts in foreign currency to own bank accounts located abroad;

vi. Definition of related entities: Regarding restrictions applicable to the export of goods and the import of goods and services to related entities, among others, entities that directly or indirectly control the local entity or entities that are directly or indirectly controlled by the same company, shall be regarded as related entities; and

vii. Financings granted by local financial entities: Financings granted by local financial entities in foreign currency to clients of the non-financial private sector shall have to be settled in the foreign exchange market at the time of disbursement of the funds.


Gabriel Gómez Giglio practices mainly in banking and finance law in the Firm’s Buenos Aires office. He is a correspondent of the Journal of International Banking Law and Regulation and International Company and Commercial Law Review. He is the author of more than 20 articles and book chapters on topics related to his area of practice published in the UK, Germany and Argentina. Gabriel is a law professor at the Universidad Torcuato Di Tella and member of the Buenos Aires Bar Association.


Francisco José Fernández Rostello is a partner and member of the Firm’s Banking & Finance Practice Group in Buenos Aires. He has worked for the International Swaps and Derivatives Association and for Société Générale, New York Branch. He is knowledgeable on matters related to issuance of debt, derivatives transactions, local and cross-border financing, and securities transactions.