Argentine Foreign Exchange Regime — General Framework Applicable to Digital Assets

The Central Bank of the Argentine Republic (BCRA) is the authority responsible for regulating foreign exchange transactions and currency transfers, defining when a transaction constitutes a foreign exchange transaction.

According to case law, the existence of a foreign exchange transaction requires:

• exchange or swap,

• between one currency and another,

• involving the Argentine national currency.

Cryptoassets are considered liquid external assets by the BCRA, within categories such as:

• holdings of foreign currencies,

• gold holdings,

• immediately liquid external investments,

• cryptoassets.

The current foreign exchange regime includes restrictions on access to the foreign exchange market when certain holdings exist or when cryptoassets have been acquired in the previous 90 days, in accordance with the regulations set forth in the Consolidated Text on Foreign Exchange and External Transactions.

The above information is presented in general terms, without linkage to the structure or activities of any particular project.