CNV Updates VASP Regulatory Framework

General Resolution 1172/2026 of the Argentine Securities Commission (CNV), issued  on October 14, 2026, replaces Chapter III of Title XIV of the CNV Rules, which governs Virtual Asset Service Providers (VASPs). The Resolution introduces several relevant modifications discussed below.

1. Incorporation of interpretative criteria

The Resolution incorporates into the CNV Rules the dispositions in Interpretative Criteria 95, 96, and 97. As a result, the CNV Rules now expressly include requirements regarding:

1. 1. companies incorporated in Argentina and branches or permanent representations of foreign companies;
   2. evidence of compliance with the minimum net worth requirement;
   3. the treatment of capital contributions and irrevocable contributions; and
   4. corporate purpose requirements applicable to VASPs, which, in the case of locally incorporated entities, must expressly provide for the performance of VASP activities.

2. Clarifications on the scope of the registration requirement

The Resolution clarifies who must register in the VASP Registry:

• Individuals: registration is only required when the relevant activities exceed 35,000 UVA per calendar month.
• Decentralized protocols providing virtual asset services: they are excluded when there is no individual or legal entity that exercises sufficient control or influence over their operation and provides services falling within the definition of a VASP.

3. Annual systems audit

The annual audit report must be signed by an IT professional with demonstrable experience in information systems and virtual asset security.

4. Referral arrangements

Referring parties may only redirect clients and facilitate contact with another provider. They may not participate in the receipt, transmission, or execution of orders.

5. New reporting regime

The Resolution expands the illustrative list of material events and creates a new monthly filing. This report must be submitted within 15 calendar days following the end of each month, and must report the number of active clients, traded volume, most traded virtual assets and assets under custody, even if no transactions were carried out during the reporting period.

6. Procedures

The Resolution establishes procedures for:

• adding new registration categories;
• cancelling registration, including voluntary deregistration, which requires prior notice to clients of at least 30 calendar days; and
• changing the corporate name, which requires updating the registration legend on the entity’s website, application, and social media accounts.

7. Strengthening AML policies

The Resolution strengthens obligations relating to the prevention of money laundering, terrorist financing, and proliferation financing (AML):

• Proliferation financing is expressly incorporated into affidavits, incompatibility rules, prevention systems, and codes of conduct.
• Convictions for the offenses in articles 303–313 of the Argentine Criminal Code are added as grounds for incompatibility.
• The offering of mixers, tumblers, and other services that hinder the traceability of transactions is expressly prohibited.

The new monthly report on clients, transactions, and custody will become mandatory as of November 1, 2026.