What is New for Foreign Companies Registering as VASPs?

On April 23, 2025, the Argentine Securities Commission (CNV) issued Interpretative Criteria 95, clarifying and interpretating the conditions foreign companies registering as Virtual Asset Service Providers (VASP) must meet to comply with the minimum net worth requirement set out in article 9 of General Resolution RG 1058/2025.

Following article 118 of the General Companies Law 19550 (LGS), RG 1058/2025 had established that foreign companies seeking to register as a VASP could establish a local subsidiary or incorporate in Argentina as a branch or any other kind of permanent representation.  Now, to meet the minimum net worth requirement, branches must have an assigned capital in Argentina, integrated and reflected in their financial statements.

On the other hand, permanent representations must prove the specific allocation of assets in Argentina by means of guarantee trusts, if capital cannot be allocated to them. To prove they comply with the minimum net worth requirement, companies must submit an independent public accountant’s report, with a legalized signature, before the corresponding controlling entity.

The CNV also published a document with Frequently Asked Questions—which it  updates on a regular basis—to answer questions about the registration process as a VASP.