Blockchain and Crypto-Assets 2026

LATIN AMERICA-WIDE Trends and Developments Contributed by: Carlos Rivas and Jose Rodríguez, Nodeman

El Salvador: regional dominance built on a regulated digital‑asset stack If the 2021 Bitcoin Law put El Salvador on the map, the 2023 Digital Asset Issuance Law ( Ley de Emisión de Activos Digitales , or LEAD) is what made it the regional reference point. LEAD established the Comisión Nacional de Activos Digitales (CNAD) as an autonomous regulator with full authority over digital assets issuances, stablecoins and tokenised RWAs – the broadest single‑statute remit in the Americas. As of early 2026, CNAD had issued more than 70 digi- tal asset service provider (DASP) licences, anchored by Bitfinex Securities (the first DASP approved under LEAD in April 2023), Bitfinex Derivatives (January 2025), and the core Bitfinex platform (May 2026). Tether, OKX and a growing roster of compliant fin- techs have also established licensed operations in San Salvador, drawn by what most industry counsel call the most business‑ready digital‑asset framework in the hemisphere. The institutional pivot accelerated on August, 2025, when the legislative assembly approved the Invest- ment Banking Law ( Ley de Bancos de Inversión ). The statute creates a dedicated licence for invest- ment banking entities ( entidades de banca de inver- sión ) authorised to provide asset management, M&A structuring, structured financing, and capital-markets distribution to Sophisticated Investors meeting the same USD250,000 liquid-asset threshold. Critically, the law expressly recognises bitcoin, tokenised sov- ereign treasury bonds and digital assets as eligible liquid assets for that test, and permits any licensed investment banking entity to operate concurrently as a digital asset service provider, digital asset issuer, and bitcoin service provider. The central reserve bank ( Banco Central de Reserva or BCR) sets capital, liquidity, risk, and digital-asset operating rules through its Standards Committee, while the Superintendencia del Sistema Financiero (SSF) handles licensing and direct supervision; the two bodies jointly recalibrate the Sophisticated Investor threshold every two years. A third pillar arrived in October 2025, with Decree No 430 – the Alternative Private Investment Funds Law ( Ley de Fondos de Inversión Privados Alternativos ). The statute creates a standalone regime for private vehicles aimed exclusively at Sophisticated Inves-

tors, requiring a USD250,000 minimum ticket and a USD50 million minimum aggregate equity at consti- tution. Property authorised investment funds (PAIFs) may be structured as a PAIF subordinado managed by a licensed management company (minimum capital USD10 million; guarantee of USD500,000 or 1% of AUM) or as a PAIF autónomo set up as a closed-end investment company ( Société d ’ Investissement à Cap- ital Fixe or SICAF). Permitted investments expressly include securities, real estate, stablecoins, and digital assets under the LEAD Law – placing tokenised RWAs squarely inside an institutional fund wrapper. The fis- cal architecture is the strategically distinctive part: PAIF profits, dividends, royalties, rents, and capital gains are exempt from Salvadoran income tax, PAIF- to-PAIF investments are also exempt, and investor distributions of USD1 million or more are not subject to withholding. The BCR issues technical norms, the SSF exercises proportional supervision, the treasury administers the tax regime, and foreign shareholders, foreign-language trade names and international audi- tors are explicitly admitted. On the public‑policy side, El Salvador holds approxi- mately 7,660 BTC in its sovereign treasury as of May 2026, worth over USD500 million, an unprecedented sovereign allocation. In November 2025, Tether’s tokenisation arm Hadron partnered with Bitfinex Securities and KraneShares to issue tokenised ver- sions of US exchange‑traded funds out of El Salvador, positioning the country as the institutional issuance venue for a tokenised‑securities market projected to grow from roughly USD30 billion in 2025 to near- ly USD10 trillion by 2030. Aggregate AUM across CNAD‑licensed DASPs is not consolidated publicly, but the licensee base and institutional pipeline have made El Salvador the de facto institutional booking centre for LATAM digital assets. Tokenisation and on‑chain credit across the region If stablecoins are the dollar layer, RWA tokenisation is the credit layer being built on top. The broader LATAM RWA market generated USD387.1 million in revenue in 2024 and is projected to clear USD1.6 billion by 2030 at a 22.7% compound annual growth rate. Brazil leads decisively, with tokenised assets surpassing BRL5.4 billion – roughly USD1 billion in assets under manage- ment on‑chain. Institutional rails are concentrating on

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