Crypto ATMs in Argentina: Registration, AML and Market Outlook

Argentina regulates crypto ATM operators through its VASP framework: CNV registration, local incorporation, UIF compliance and customer identification from the first transaction. No rules are specific to ATMs. With USD 88.5 billion in crypto activity in the year to June 2026, Argentina is Latin America’s second-largest crypto economy, yet very few machines serve it.

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Last updated: October 2026

A Registration Framework Without ATM-Specific Rules

Argentina regulates crypto ATM operators through its general framework for virtual asset service providers (VASPs). Three instruments introduced in 2024 and 2025 set the rules:¹

• Law 27,739 (March 2024): defines VASPs, creates a mandatory registry under the Comisión Nacional de Valores (CNV), and adds VASPs to the list of entities with anti-money laundering obligations under Law 25,246.³
• CNV General Resolution 1058/2025: the comprehensive VASP framework, with five service categories, minimum net worth requirements, cybersecurity obligations, fund segregation rules and reporting standards. Full enforcement applies from 31 December 2025.⁴
• UIF Resolution 49/2024: the core AML/CFT regulation for VASPs, based on a risk-based approach. It lists "cajeros automáticos" among the distribution channels that providers must cover in their AML risk assessment, so regulators are aware of the channel even though no dedicated ATM rules exist.⁵

An operator exchanging fiat currency for virtual assets at a machine would typically fall under Category 1 (exchange between virtual assets and fiat currencies). Anonymous accounts are prohibited and there is no minimum amount below which a client does not have to be identified.⁶ ¹⁴

Licensing: VASP Registration, Local Incorporation and UIF Compliance

Before placing a machine, an operator has to complete three parallel registration processes.

CNV VASP registration is the primary requirement. It requires local incorporation as an SA or SRL under Argentine law, or a registered branch or permanent representation of a foreign entity.⁷ The CNV side requires a regulatory compliance and internal control officer (Responsable de Cumplimiento Regulatorio y Control Interno) and a public relations officer (Responsable de Relaciones con el Público). The UIF side requires a principal and an alternate compliance officer (oficial de cumplimiento titular y suplente).⁴ ¹¹ Minimum net worth for Categories 1, 2 and 4 is USD 150,000, reduced by 50% for providers with less than USD 2.5 million in transaction volume over the previous 12 months.⁴ The CNV annual supervision fee for a legal entity is ARS 13,360,000 for 2026.⁹ Advisers estimate around four to six months from company formation to a completed CNV review.¹⁰

Within 30 days of CNV registration, operators must also register with the Unidad de Información Financiera (UIF) and register their compliance officers with it.¹¹ UIF registration itself is free. Building the required compliance infrastructure is not.

Additional registrations include ARCA (the tax authority that replaced AFIP) for income tax and VAT, the AAIP for personal data protection, and provincial and municipal business licences for each ATM location. No separate BCRA authorisation is currently required for standalone VASP operations.¹²

Estimated setup costs range from USD 305,000 to USD 515,000 for an initial fleet of 5 to 10 machines, including minimum net worth, legal fees, compliance infrastructure, equipment and first-year operations. Annual compliance costs run USD 48,000 to 85,000.¹³

AML and KYC Obligations From the First Transaction

UIF Resolution 49/2024 sets no monetary threshold for customer identification. Even simplified due diligence for low-risk clients still requires identification and verification.¹⁴ In practice, every crypto ATM transaction requires identifying and verifying the customer with an identity document such as an Argentine DNI, plus identification of the beneficial owner where the client is a legal entity. PEP screening and checks against the RePET terrorism registry (Registro Público de Personas y Entidades vinculadas a actos de Terrorismo y su Financiamiento) are mandatory.¹⁵

A suspicious transaction report on money laundering must be filed within 24 hours of the provider concluding that an operation is suspicious, and no later than 90 calendar days after the operation. Reports on terrorist financing are due within 24 hours of the operation. Monthly systematic reports, filed between the 1st and 15th of each month, cover every operation at or above six times the monthly minimum wage (SMVM).¹⁶ The SMVM is ARS 391,200 in October 2026 and rises each month under Resolution 4/2026, which puts the threshold at about ARS 2.35 million this month.²⁸ An annual report covering the previous calendar year is due between 2 January and 15 March.¹⁶

Resolution 49/2024 requires each provider to apply reinforced monitoring to cash deposits, and deposits of six SMVM or more also require identifying the depositor.¹⁷ Operators also need transaction monitoring and blockchain traceability tools, a written AML/CFT prevention manual and an annual review by an external independent reviewer.¹⁸

Banking Access: Feasible, But Not Frictionless

A registered VASP can obtain a corporate bank account, but advisers estimate this adds four to six weeks to setup and usually requires professional assistance.¹⁹ No Argentine bank has publicly positioned itself as crypto-friendly, and operators should expect enhanced documentation on source of funds, AML/CFT policies and business reputation.

The BCRA prohibits banks (Communication A 7506, May 2022) and payment service providers offering payment accounts (Communication A 7759, May 2023) from offering crypto services to their own customers. This prohibition does not stop banks from keeping basic banking relationships with registered crypto companies, which is why banking access is possible at all.²⁰

A Large Crypto Market With Very Few Machines

Argentina is the second-largest crypto economy in Latin America, with USD 88.5 billion in crypto activity in the 12 months to June 2026, up 15.3% and behind only Brazil.²⁷ Years of currency instability have pushed many households toward dollar-denominated stablecoins as a way to save.

The ATM channel, by contrast, is barely developed. Public map listings show only a handful of crypto ATM locations in the country, and their working status could not be confirmed.² Argentina keeps no official public register of deployed machines. For an operator, the gap between strong crypto demand and very limited physical distribution is the main reason to look at Argentina, and the licensing requirements described above explain why the gap has not yet been closed.

Future Outlook (2026–2027)

The regulatory direction under the Milei administration is broadly favourable to crypto, and the CNV's VASP framework is expanding. The BCRA's prohibition on banks and payment service providers offering crypto services to their customers (Communications A 7506 and A 7759) remains in force. On 7 October 2026, the Superintendent of Financial and Exchange Entities said it will not change this year and described a lifting as possible in a second Milei term.²⁶ Currency controls were lifted for individuals from 14 April 2025, while some restrictions remain for companies,²¹ and Argentina passed its 2024 FATF mutual evaluation without being grey-listed.²²

Three risks temper the outlook. The $LIBRA memecoin, promoted by President Milei in February 2025, crashed within hours, and traders lost an estimated USD 251 million, which has increased political sensitivity around crypto.²³ Regulatory pressure on crypto ATMs is growing abroad: German authorities seized 13 machines in August 2024, New Zealand announced a ban in 2025 and replaced it in July 2026 with powers to restrict cash transactions, and in February 2025 the UK issued its first prison sentence for operating crypto ATMs without registration.²⁴ The VASP framework itself is recent, and enforcement practice is still developing.²⁵

Sources and references:

1. Gofaizen Sherle & Signzy, 2. Bloomberg Línea — Cajeros cripto pierden auge: así quedó la lista de países con más ATM en Latinoamérica a 2026 (Coin ATM Radar listings, 21 August 2026; listings do not confirm working machines), 3. Boletín Oficial — Ley 27.739 (15 March 2024) & Sumsub, 4. CNV Resolución General 1058/2025 (Boletín Oficial, 14 March 2025) (categories, minimum net worth and 50% reduction, officers, 31 December 2025 enforcement) & Gofaizen Sherle, 5. Bomchil & UIF Resolution 49/2024 (Boletín Oficial) (art. 4(c), distribution channels), 6. Beccar Varela, 7. CNV RG 1058/2025 — S.A./S.R.L. requirement and art. 118 branch route & General Companies Law 19,550, 8. Legasset Law Company, 9. CNV — Tasas de fiscalización y control (PSAV, persona jurídica, 2026), 10. Gofaizen Sherle, 11. Bruchou & Funes de Rioja & DLA Piper, 12. Decreto 953/2024 — AFIP dissolved, ARCA created & Ally Law, 13. General Bytes Internal Cost Analysis, 14. UIF Resolution 49/2024, arts. 21–27 (no de-minimis exemption from client identification; anonymous accounts prohibited; simplified due diligence still requires identification) & Lightspark, 15. Bruchou & Funes de Rioja, 16. UIF Resolution 49/2024, arts. 36 and 39 (Boletín Oficial) & Beccar Varela, 17. UIF Resolution 49/2024, art. 38 (Boletín Oficial) & Bomchil, 18. UIF Resolution 49/2024, art. 19 (Boletín Oficial) & DLA Piper, 19. Gofaizen Sherle, 20. Signzy & Ally Law, 21. Ámbito — Para las empresas, el final del cepo deberá esperar (14 April 2025), 22. FATF — Mutual Evaluation Report of Argentina (2024) & Marval O'Farrell Mairal, 23. The Block — Traders of LIBRA memecoin lost $251 million (Nansen) & Buenos Aires Times, 24. AML Intelligence (Germany, August 2024) & FCA press release, February 2025 (UK's first conviction for operating an unregistered crypto ATM network) & 1News (New Zealand ban withdrawn, 9 July 2026), 25. Ainvest, 26. Criptoinforme — BCRA y cripto en bancos: no habrá cambios en 2026 (8 October 2026) & iProUP (12 October 2026), 27. Chainalysis — 2026 LATAM Crypto Adoption (USD 88.5bn crypto activity, 12 months to 30 June 2026, +15.3%; second in the region behind Brazil; published 23 September 2026), 28. Infobae — Salario mínimo en octubre 2026 (ARS 391,200 from 1 October 2026, Resolution 4/2026)

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Argentina's VASP framework is recent, the SMVM-based reporting threshold changes every month, and the BCRA's restriction on banks and payment service providers offering crypto services to customers remains in force. Always consult specialised Argentine legal counsel before considering market entry. Information current as of October 2026.