Fintech 2026

ARGENTINA Law and Practice Contributed by: Santiago J. Mora, Nicolas Garfunkel, Milagros Caneda and May Steward, GPG Advisory Partners

on PSAVs carrying out the activities described in the preceding paragraph are: • compliance with a minimum net worth requirement of up to USD150,000; • the adoption of a code of conduct; • the implementation of systems aimed at prevent - ing, detecting and reporting financial crime risks, including money laundering and terrorist financing, together with corresponding prevention policies; • the adoption of procedural manuals governing systems and operations; • the appointment of various responsible officers; and • the submission of audit reports on the systems used by the PSAV, in addition to regulatory compli - ance and internal control reports. 6.4 Listing Standards On the one hand, PSAVs may only offer AVs that include general information in a “white paper” and/ or other informational materials containing relevant information about the issuer and the project, among other matters. Such information must be published or made available on the PSAV’s website and/or mobile application and must be accessible and available at all times in Spanish or in English. Likewise, only those AVs whose launch occurred less than 90 days prior may be made available to users on the PSAV’s platform and/or mobile application, provided that they include a special warning indicat - ing that, due to their recent launch, they may entail volatility, a risk of total loss of the amounts allocated to them, and, in general, a level of risk that may in all cases be potentially higher than that of other AVs with a longer track record. Such AVs must, at least during such period, be presented in a specific section of the PSAV’s platform and/or mobile application. Finally, PSAVs may not offer securities that have not been approved by the CNV, in accordance with the regime set forth in CNV Resolutions No 1069, 1081 and 1087 (see 1.1 Evolution of the Fintech Market ). On the other hand, within the context of equity crowd - funding mentioned in 6.1 Permissible Trading Plat- forms , equity crowdfunding platforms must review

and select the projects that will be offered for financ - ing. For this purpose, a project selection guide must be prepared that must include objective, reasonable and non-discriminatory parameters applying measur - able and consistent criteria. In addition, the platform must contemplate procedures to inhibit or cancel CNV rules set down the guidelines on how agents must execute orders placed by investors. In this respect, it is established that orders must be executed in the terms given by the clients and promptly entered into the order registration system of the market. Fur - thermore, the agents are required to have procedures in place that allow them to enter orders into the com - puter trading system of the interconnected market where the best market conditions are available to their clients, while the system used by the agent for the placement of orders must ensure the accurate regis - tration of the order in the transaction ticket. potentially fraudulent projects. 6.5 Order Handling Rules In addition, the CNV has specific rules for equity crowdfunding (see 6.1 Permissible Trading Plat- forms ). Also, within the framework established by CNV Reso - lution No 1058, PSAVs are required to adopt internal procedures governing the receipt, registration and execution of clients’ orders involving AVs. PSAVs must ensure that orders are processed in accordance with clients’ instructions and that each transaction is promptly and accurately recorded in electronic sys - tems that ensure full traceability, including, at a mini - mum, the date and time of the transaction, the type and amount of the AV, the identification of the client, and the corresponding transaction identifier (where applicable, the hash or transaction ID). In addition, PSAVs must act in good faith and with due care, prioritising clients’ interests and avoiding conflicts in the handling of orders, including by refrain - ing from executing transactions for their own account when client orders of the same nature are pending. PSAVs operating platforms, wallets or applications must have systems and controls in place to ensure the correct and traceable processing of transactions and the maintenance of auditable electronic records.

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