Fintech 2025

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

Exchange Commission ( Comisión Nacional de Valores or CNV). Looking ahead, the fintech sector is expected to continue growing and developing in the next 12 months, with an increase in the number of transactions, customers and businesses. This is mainly because of the recent change of admin - istration in the federal government, which leans towards promoting citizens’ liberties and free - dom of choice in the market, and also because of the good projections in terms of macroeconomic regularisation. At the same time, the regulatory framework is expected to continue evolving and adapting, particularly as the current authorities have actively encouraged public-private dia - logue to support these developments. 2. Fintech Business Models and Regulation in General 2.1 Predominant Business Models In Argentina, the payments, crypto and lending verticals are the predominant business models. In the payments vertical, emerging businesses are innovatively using technology and com - bining it with traditional businesses to speed up, expand and consolidate different payment mechanisms into a single platform, reducing the cost of payment processes. In the crypto vertical, most crypto-asset exchanges operating in Argentina allow their users to acquire various types of cryptocurren - cies and provide access to decentralised finance (DeFi) products. In the crypto vertical, the Argentine Central Bank ( el Banco Central de la República Argentina or BCRA) hinted at the possibility of banks regain -

ing authorisation to trade cryptocurrencies, an authorisation that was revoked in 2023. This possibility would not only benefit banks, but also other fintechs that develop services for businesses, as they could become traditional banks’ crypto partners. Moreover, the enterprise financial management vertical experienced significant growth, mainly driven by the emergence of solutions focused on financial management and business intelligence. The adoption of APIs and modular architectures has become a key trend. In addition, there have been important new pro - jects and start-ups in the regtech sector and in the provision of IT services to financial institu - tions and fintech companies, as well as in the use of blockchain technology. 2.2 Regulatory Regime There is no centralised regulatory framework governing the entire fintech ecosystem in Argen - tina. Instead, there are separate regulations scat - tered throughout the legal system, with some issues receiving more detailed regulation than others. In the following paragraphs, we review the main regulations that apply to the main fin - tech verticals. Payments Verticals The Credit Cards Law No 25,065 (CCL) applies not only to credit card payment systems but also to debit cards, “exclusive purchase cards” and any other payment system related to credit card operations. Financial Entities Law No 21,526 (FEL) applies to financial entities that provide payment services. Before 2020, e-money systems were not expressly covered by any specific regulation within the Argentine domestic legal framework.

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