New Regulation for Virtual Asset Service Providers (VASPs)

Through General Resolution No. 1058/2025, dated March 14th, 2025 (the “Resolution”), the Argentine Securities Commission (“CNV”, for its Spanish acronym) issued new regulations applicable to Virtual Asset Service Providers (“VASPs”), which will take effect on May 26th, 2025.

The Resolution establishes that individuals or entities engaging in activities falling within the definition of VASPs must obtain registration with the Virtual Asset Service Providers Registry (the “VASPs Registry”) before commencing operations. Below are the key aspects of the Resolution:

1. Definition of VASPs: Individuals or legal entities engaging in any or all the following activities:
   1. Category 1: Exchange between virtual assets and legal tender (fiat currency).
   2. Category 2: Exchange between one or more forms of virtual assets.
   3. Category 3: Transfer of virtual assets.
   4. Category 4: Custody and/or administration of virtual assets or instruments that enable control over them (provided that they are not non-custodial).
   5. Category 5: Participation in and provision of financial services related to the offering and/or sale of a virtual asset by an issuer[1].
2. Registration Requirements. The Resolution introduces new registration requirements[2] for the VASPs Registry, distinct from those established under CNV Resolution No. 994/2024. These requirements will apply both to VASPs seeking registration for the first time and to those already registered at the time the Resolution comes into effect.
3. Establishment of a Local Branch or Entity. VASPs incorporated abroad must register with the Public Registry of Commerce in accordance with Section 123 of the Argentine Companies Act and establish a local entity or set up a branch, office, or any form of permanent representation in compliance with Section 118 of the Argentine Companies Act.
4. Minimum net worth requirement. When applying for registration in the VASPs Registry, VASPs must demonstrate compliance with the minimum net worth requirement pertaining to the category in which they will be registered. If registering under multiple categories, VASPs must meet and prove the highest applicable minimum net worth requirement.
   a. Categories 1, 2, and 4: USD 150,000 (one hundred fifty thousand U.S. dollars)
   b. Category 3: USD 75,000 (seventy-five thousand U.S. dollars)
   c. Category 5: USD 35,000 (thirty-five thousand U.S. dollars)
5. Cybersecurity policy. VASPs must develop policies and manuals detailing the IT systems used in their operations, as well as cybersecurity policies aimed at establishing internal procedures for managing cyber risks. These policies must be audited annually by independent experts.
6. Fund segregation. VASPs must maintain a clear separation and identification of funds used in their business operations, distinguishing between funds derived from or allocated to client transactions and those related to proprietary transactions.
7. Delegation of activities to third parties. VASPs may delegate the custody and/or administration of their clients’ virtual assets, provided that such services are carried out through an open wallet. VASPs may also delegate activities inherent to their role as VASPs, as long as the agreements include an obligation to provide all necessary information to comply with reporting requirements. If the delegation is made to a foreign VASP, the latter must be regulated by the supervisory authorities of its home country.
8. Systematic reports. VASPs must submit systematic reports to the CNV on a monthly and annual basis, detailing the wallets used for the custody of their clients’ virtual assets, the number and type of clients, transaction volumes, and the most traded and/or custodied virtual assets. The first report must be submitted by November 10th, 2025.
9. Advertising. VASPs must refrain from promoting, advertising, and/or spreading activities related to the capital markets, and vice versa. Additionally, VASPs may not offer or intermediate in transactions that represent a public offering of virtual assets classified as securities, unless such assets have been granted public offering authorization by the CNV.
10. Offering of virtual assets. VASPs may only offer virtual assets that have been in existence for more than 90 days, unless they explicitly disclose that the asset is newer and, as a result, may be subject to higher volatility and increased risk.
11. Transparency. VASPs must maintain a transparent fee structure regarding the services they provide to the general retail public.
12. Website blocking. The CNV may request judicial authorities to block the websites of legal entities engaging in VASP activities without the required registration in the VASPs Registry.

The Resolution establishes a transition period for VASPs already registered in the VASPs Registry at the time it comes into effect to comply with the new registration requirements. The deadlines are as follows: (i) August 1st, 2025, for locally incorporated entities, and (ii) September 1st, 2025, for foreign entities. After these deadlines, CNV will require the cancellation of registrations for VASPs that have not updated their registration in the VASPs Registry. All other obligations set forth in the Resolution will become enforceable as of December 31st, 2025.

[1] Entities providing services through platforms and/or mobile applications to issuers for the initial offering of Virtual Assets and/or as a public means of raising funds for project financing will be included in this category. However, the mere act of issuing a Virtual Asset by an issuer will not fall within the scope of this provision.

[2] The most relevant include:(i) Incorporation of a local entity to operate in Argentina[1], (ii) Identification of the fiscal year-end date and proof of compliance with the applicable minimum net worth requirement, (iii) sworn statement by the VASP’s authorities confirming they have not been convicted of money laundering offenses, (iv) bylaws of the administrative body certifying that the VASP has the necessary organizational structure to operate, (v) identification of compliance officers within the VASP, and (vi) report from an IT specialist certifying the proper functioning of the entity’s cybersecurity systems.