Case study
Wanel Lithuania
Services Provided: End-to-end VASP formation in Lithuania, including company setup, AML/KYC and MiCA compliance frameworks, licensing support, HR recruitment, payroll, and accounting assistance.
Quick actions
Argentina requires covered virtual asset service providers (PSAVs) to register with the National Securities Commission (CNV) before operating.
May not fit
| Applicant | Argentine Connection | Route and Legal Form | Limitation |
| Local entity | Covered local services | Corporation (SA) or limited liability company (SRL) | Individual threshold does not apply |
| Foreign provider | Any qualifying Argentine connection | Article 118 branch or permanent representation | Check each connection |
| Foreign group through local entity | Local registrant serves clients | Article 123 shareholding differs from an Article 118 branch | Parent exclusion is conditional |
| Resident individual | Over 35,000 UVA per calendar month | Individual registration | Categories 1–2 only |
UVA is Argentina’s inflation-indexed unit, used to calculate the registration threshold for resident individuals. Different rules apply to foreign companies.
Under Article 4 of the CNV’s PSAV rules, foreign companies must register if they meet any of these conditions:
Article 4 defines the local connections that bring foreign providers within Argentina’s registration requirements.
A foreign company holding an interest in an Argentine PSAV, directly or through its group, may qualify for the intragroup exemption. It must have no direct contracts with Argentine clients and meet none of the conditions above.
Categories determine net worth:
Category 1: exchange between virtual assets and government-issued money.
Category 2: exchange between virtual assets.
Category 3: transfer of virtual assets.
Category 4: custody or administration, excluding exclusive user control.
Category 5: financial services around an issuer’s offer or sale, excluding issuance alone.
Individuals may use only Categories 1–2. Categories 3–5 require a corporate applicant.
Our expertise
Gofaizen & Sherle’s general services include assessing activities, structuring entities, developing compliance frameworks and agreed ongoing support.
Gofaizen & Sherle prepares documents using information you provide.
You and Argentine corporate and accounting specialists document ownership and net worth.
While you set up internal controls, Gofaizen & Sherle coordinates required IT audits and helps respond to CNV inquiries throughout the registration process.
Gofaizen & Sherle helps you answer regulatory questions within the agreed scope. CNV decides registration. UIF oversees anti-money laundering and counter-terrorist financing obligations.
| Cost | Work or Payment | What to Confirm |
| Professional fee | Assessment, corporate and filing documents, compliance work | Individually quoted work and exclusions |
| Official charges | 2026 annual CNV supervision levy | ARS 13,360,000 for companies, ARS 5,344,000 for individuals |
| Third-party costs | Local corporate, accounting, translation, IT and audit work | Itemize in quote |
| Ongoing operations | Staffing, controls and reporting | Operating costs |
| Net worth | Business financial resources | Not a fee |
New registrants pay the annual levy within five business days after registration. It is not an application fee.
You and Gofaizen & Sherle review your planned activities and identify the appropriate registration route.
You and local specialists complete the corporate steps required for the chosen applicant structure.
You, an accountant, and an IT professional prepare documents showing your financial resources and internal controls.
You submit the application with the required documents.
You and Gofaizen & Sherle respond to CNV requests and make any required corrections.
CNV completes its review and decides whether to register you as a PSAV.
You implement compliance procedures, arrange banking services, and obtain any additional approvals required for your activities.
Provide corporate records identifying owners, ultimate beneficial owners and managers.
Describe activities, customer markets and turnover to determine applicable rules.
Individuals need an independent accountant’s certified assets-and-liabilities statement. Companies need audited financial statements. If your audited financial statements are more than eight months old at the time of final submission, an independent certified public accountant must confirm your figures. In this case, your certified net worth statement must be dated within two months prior to filing.
IT, custody, outsourcing, client-asset and anti-money-laundering (AML) records demonstrate operational controls.
Preparation timelines depend on documentation readiness and specialist inputs, while review schedules remain at the CNV’s discretion. Submitting an application does not confer operating rights, and unresolved regulatory requests keep the file pending.
Law 27,739 establishes CNV’s PSAV powers within the framework of Law 25,246. UIF sets anti-money-laundering and counter-terrorist-financing rules under Resolution 49/2024. Securities and central-bank rules remain separate.
| CNV Event | Date | Practical Consequence |
| RG 1172 Published | 15 October 2026 | Enacts the updated PSAV supervisory framework. |
| Current Framework Enacted | 16 October 2026 | Establishes current net worth thresholds and custody safeguards. |
| Monthly reporting start date | 1 November 2026 | Start date for the monthly reporting regime, not the first filing deadline. |
| Categories | Minimum Net Worth |
|---|---|
| 1, 2, 4 | $150,000 |
| 3 | $75,000 |
| 5 | $35,000 |
Categories 1–3 receive a 50% reduction when transaction volume over the preceding 12 months is strictly below USD 2.5 million. Category 4 uses custody volume. Category 5 has no reduction. Multiple categories use the highest applicable requirement.
CNV continuously
Maintain resources, follow conduct rules and apply required client-asset controls. Category 4 requires custody safeguards and proof of reserves. Client assets cannot fund the provider’s own activity.
CNV annually
Submit the annual audit, signed by an IT specialist experienced in systems and virtual asset security, and the regulatory officer’s report within 70 calendar days after calendar year-end.
Records
Keep relevant CNV records for at least ten years. UIF retention periods run from the applicable transaction or client-relationship event.
CNV monthly
PSAV_014 is the monthly CNV report covering clients, transactions, and cryptoassets held in custody. Operating providers must submit it within 15 calendar days after month-end, even with zero activity. Registered providers that have not started operating instead submit PSAV_015, a notification confirming that status.
UIF
Maintain risk-based controls against money laundering, terrorist and proliferation financing, customer and beneficial-owner checks, monitoring and separate monthly, systematic and annual reports. The annual risk assessment and external review are separate from the IT audit. Article 37 addresses sender and recipient information under the Travel Rule.
Covered unregistered activity is prohibited. CNV may enforce the rules and ask courts or prosecutors to block URLs or social media for possible unlawful activity. Misleading registration claims and advertising are prohibited. AML sanctions also apply.
Registration does not guarantee a bank or payment account. Central bank (BCRA) restrictions on banks’ and payment-account providers’ crypto services still apply. They do not generally prohibit PSAV accounts.
For the provider’s review, prepare regulatory documents, ownership and source-of-funds information, expected flows of traditional money and client-money controls. Banking assistance requires agreement.
Argentina’s national tax agency, ARCA (Agencia de Recaudación y Control Aduanero, which replaced AFIP), applies distinct tax treatments to corporate entities and individual operators. Corporate net taxable income is subject to progressive rates of up to 35% under Article 73 of the Income Tax Law. Depending on your operational flow, you should also evaluate the potential application of Value Added Tax (VAT) and the tax on bank debits and credits. Note that the temporary asset-regularization tax regime introduced for 2024–2025 is now closed to new declarations.
| Country or Region | Legal Output | Capital or Resources | Access and Limitation |
| Argentina | Registration | Category amounts above | Argentina, with separate banking and securities permissions |
| Panama | Separate legal assessment required | Determine for the model | Regulator, permission and market access require assessment. Incorporation does not establish crypto authorization |
| El Salvador | Registration certificate and operating authorization | Financial suitability assessed by service model | Domicile or active marketing triggers the rules. Foreign applicants need a local SA or branch. Payment and issuer permissions are separate |
| European Union | Service-specific authorization under MiCA, the EU crypto-asset regime | Greater of service-based EUR 50,000/125,000/150,000 (MiCA Annex IV) and 25% prior-year fixed overheads. First-year projections. Own funds, insurance or guarantee | Union services after cross-border notification. Article 60’s financial-entity route differs |
| Montana | FinCEN registration for covered money services businesses (MSBs), subject to exemptions. Not a crypto license | Assess resource requirements for any additional licenses | Montana does not regulate money transmitters. Other activities may require Montana licenses. FinCEN registration does not grant nationwide operating permission |
CNV PSAV registration is required before covered services begin.
Yes. Use the highest applicable net-worth requirement for all covered services, without adding amounts.
Yes. Another qualifying connection can trigger the rules even below the business-volume threshold.
Yes. Operating providers must file Form PSAV_014 within 15 calendar days after month-end even with zero transaction volume. Registered entities that have not yet launched commercial operations file Form PSAV_015.
No. UIF financial-crime controls and reports remain separate from CNV supervision.
No. Each provider decides whether to accept the business.
Client Testimonials
Excellent service! The communication is fast and friendly, we are very satisfied with received comprehensive package of services such as legal consulting, full turnkey crypto company formation in Lithuania, assistance in bank account opening for "high risk" business, human resources acquisition etc. Highly recommended!
Roman Potemkin
Founder & CEO. TRASTRA
Case study
Services Provided: End-to-end VASP formation in Lithuania, including company setup, AML/KYC and MiCA compliance frameworks, licensing support, HR recruitment, payroll, and accounting assistance.
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