Exceptions for Transfers Abroad Now Expanded

On November 28, 2025, the Argentine Securities Commission (CNV) issued General Resolution 1093/2025, which replaces the CNV Rules, Title XVIII, Chapter V, article 6° TER. The measure updates agent checks and daily operating limits for transactions covered by the BCRA’s Exterior y Cambios regime and readjusts exceptions applicable to transfers to foreign depositaries, sales, and other transactions settled in foreign currency.

Purpose and scope

The new article 6° TER applies to orders and the recording of transactions on authorized markets, including transfers of negotiable securities issued by residents to foreign depositaries and other transactions set out in items 3.16.3.1 and 3.16.3.2 of the BCRA Consolidated Text Exterior y Cambios. It covers clients with CDI/CIE (non-intermediaries), regulated foreign intermediaries, and clients with an Argentine tax ID.

Operating limits and checks

Agents (AN, ALyC, ACVN) must verify that the daily volume traded does not exceed ARS 200,000,000 per: 
1.    foreign client with CDI/CIE acting for its own account and proprietary funds,
2.    regulated foreign intermediary, per each local third party or for own account,
3.    clients with Argentine tax ID acting on a “for and on behalf of” basis for third parties (consolidated limit). 

The Argentine Financial Information Unit guidelines and Title XI also apply. The control applies per each client sub-account and, in the aggregate, where the same person is holder or co-holder of multiple sub-accounts. 

For calculation purposes: 
1.    conversion between shares and CEDEAR/ADR is deemed a transfer,
2.    for purchases, the price used is the agreed one,
3.    transfers abroad, conversions, and sales settled in foreign currency use the prior day ARS price.

Exception I: issuer transfers to foreign depositaries

Agents are not required to observe the ARS 200 million limit to process issuer transfers abroad where the transaction involves:

•    Securities with (total or partial) amortization ≥ 2 years from issuance.

•    Argentine Treasury securities with amortization ≥ 180 days.

•    BOPREAL issued by the BCRA.

All this provided that the prior credit derives from a primary placement or auction, up to the face value (VN) subscribed. This also applies where the transfer falls under items 3.16.3.6.v) and 4.8.2 of Exterior y Cambios (subject to prior verification and with supporting documentation).

New exception for reinvestment of servicing proceeds (Argentine Treasury)

An additional exception is introduced for Argentine Treasury securities (regardless of governing law and amortization term) previously acquired and credited as a result of the reinvestment of servicing proceeds (payable in ARS in Argentina) from other Treasury securities with amortization ≥ 180 days from issuance and subscribed in the primary market, up to the amount of such servicing proceeds and the proceeds of their successive reinvestments. For these, verification and retention of supporting evidence (acquisition, collection of servicing proceeds, and reinvestment) are required. This exception applies to transfers made as of December 1, 2025.

Exception II: open-end mutual funds in foreign currency

Open-end mutual funds denominated in foreign currency are exempt when, exclusively to meet redemptions, they must carry out transactions covered by the article.

Exception III: on-shore sales

The limit also does not apply to on-shore sales of:

•    BOPREAL acquired in the primary market, up to the face value subscribed.

•    Securities settled in foreign currency and foreign jurisdiction, pursuant to items 4.3.2.3 (second paragraph) and 4.8.3 (second paragraph) of the BCRA consolidated text Exterior y Cambios, subject to verification and retention of supporting documentation.

Exception IV: UVA mortgage loans

On-shore sales are allowed for securities settled in foreign currency and local jurisdiction, previously acquired in ARS by residents with funds from UVA mortgage loans, up to the loan amount, provided that the proceeds are applied to the purchase of real estate in Argentina. Verification and documentation in client files are required.