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In brief

On 25 March 2024, the National Securities Commission (CNV) issued General Resolution No. 994/2024 (“Resolution“), which regulates the Registry of Virtual Asset Service Providers (“Registry“) in line with the provisions of Section 38 of the recently amended Law No. 25246 (“Law“). This Law had incorporated virtual asset service providers (VASPs) as AML/FT-regulated entities.

In depth

On 15 March 2024, Law No. 27739, which modifies the legal framework to prevent money laundering, terrorism financing and the proliferation of weapons of mass destruction, was promulgated, substantially updating the applicable regulations. One of the modifications is aimed at defining virtual assets and VASPs, and at incorporating them as reporting parties before the Financial Information Unit. In this context, the CNV issued the Resolution, by which the actions of VASPs are regulated. The Resolution provides the following rules:

  1. Individuals and legal entities residing or incorporated in Argentina carrying out one or more of the activities or operations included in Section 4 of the Law as amended must register with the Registry prior to the performance of those activities or operations.

The activities contemplated in said section of the Law are the following: (a) exchanging virtual assets and legal tender currencies (fiat currencies); (b) exchanging one or more forms of virtual assets; (c) transferring virtual assets; (d) having custody and/or administering virtual assets or instruments that allow control over them; and/or (e) participating in and providing financial services related to the offer of an issuer and/or the sale of a virtual asset (“Activities“).

  1. Individuals and legal entities residing or incorporated outside Argentina carrying out one or more of the Activities must register with the Registry prior to carrying out those Activities, provided that they perform them under any of the following modalities: (a) they use any “.ar” domain to carry out their Activities; (b) they have commercial agreements with third parties, subsidiaries or related parties that allow them to locally receive funds or assets from Argentine residents to perform the Activities (or any activity similar to those known as ramp services); (d) they clearly target Argentine residents; (e) they carry out advertising campaigns clearly aimed at Argentine residents; and/or (f) their turnover in Argentina exceeds 20% of their total turnover. For this purpose, only the total turnover of the activity or activities for which the company must be registered shall be considered.

To register with the Registry, VASPs must provide certain information and documentation stated in the Resolution.

The Resolution establishes that VASPs that carry out the Activities are exempted from the obligation to register with the Registry provided that they do not exceed, on an aggregate basis, an amount equivalent to 35,000 UVAs (acquisitive value units) per calendar month.

In addition, the Resolution clarifies that registering with the Registry does not imply that the CNV will grant a license over the Activities.

Finally, VASPs covered by the Resolution that, as of the date of its entry into force, are carrying out any of the Activities must apply to register with the Registry within 45 days from the Resolution’s date of entry into force.

The Resolution became effective on 25 March 2024. 

Spanish version


Gabriel Gomez-Giglio is partner at Baker McKenzie’s Buenos Aires office, chair of the Latin America Banking & Finance Practice of Baker McKenzie and a member of the Global Steering Committee of the Firm’s Financial Institutions Industry Group. He advises clients on a variety of general commercial issues. His practice focuses on the areas of transactional and regulatory matters, including but not limited to multinational financial transactions, commercial agreements and mergers and acquisitions. Gabriel is a member of the Board and Adjunct Professor of Law at Universidad Torcuato Di Tella and a visiting professor with the Centre for Commercial Law Studies, Queen Mary College, University of London.


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.


Jeronimo Argonz is an Attorney at law in Baker McKenzie, Buenos Aires office.


Juana Allende is an Attorney at Law in Baker McKenzie, Buenos Aires office.

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