Region

Jurisdiction

Regulator

2026-03-27 | A 8415

Circular RUNOR 1-1953 Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Processing of Foreign Exchange Proceedings (Law 19.359). Update.

The Central Bank of the Argentine Republic (BCRA) issued Communication A 8415 to update and incorporate revised sheets into the consolidated text governing its Disciplinary Regime and Foreign Exchange Proceedings under Laws 21.526, 25.065, and 19.359. The regulation establishes a detailed infringement catalog with maximum sanction units for Group A and Group B entities, defines graduated fine scales based on quantified benefits, and introduces specific disqualification measures for natural persons committing very high, high, or medium severity infringements. It mandates that preventive areas justify infringement classifications and provisional scores in their conclusion reports, while making updated texts with highlighted modifications available on the BCRA website.

Argentina

Banco Central de la Republica Argentina

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION “A” 8415 27/03/2026 TO FINANCIAL ENTITIES, TO TRUSTEES OF FINANCIAL TRUSTS INCLUDED IN THE FINANCIAL ENTITIES LAW, TO CREDIT PORTFOLIO ADMINISTRATORS OF EX-FINANCIAL ENTITIES, TO REPRESENTATIVES OF FOREIGN FINANCIAL ENTITIES NOT AUTHORIZED TO OPERATE IN THE COUNTRY, TO EXCHANGE OPERATORS, TO NON-FINANCIAL COMPANIES ISSUING CREDIT CARDS, TO NON-FINANCIAL COMPANIES ISSUING PURCHASE CARDS, TO OTHER NON-FINANCIAL CREDIT PROVIDERS, TO ELECTRONIC CLEARING HOUSES, TO AUTOMATED TELLER MACHINE NETWORKS, TO PAYMENT SERVICE PROVIDERS, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO PEER-TO-PEER CREDIT PLATFORM PROVIDERS, TO FINANCIAL MARKET INFRASTRUCTURES, TO VALUE TRANSPORT COMPANIES, TO ELECTRONIC FUND TRANSFER NETWORKS, TO PAYMENT SERVICE PROVIDERS PERFORMING THE INITIATION FUNCTION, TO ADMINISTRATORS OF ELECTRONIC FUND TRANSFER PAYMENT SCHEMES, TO PLATFORMS FOR SME FINANCING, PAYMENT ACCEPTORS WITH TRANSFER, CARD PAYMENT ACQUIRERS, AGGREGATORS OF PAYMENT INSTRUMENTS, NON-BANK TAX AND/OR SERVICE COLLECTION COMPANIES: Ref.: Circular RUNOR 1-1953: Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Processing of Foreign Exchange Proceedings (Law 19.359). Update.

We address you to deliver the attached sheets, which replace those previously provided and must be incorporated into the consolidated text on the Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Processing of Foreign Exchange Proceedings (Law 19.359), based on the provisions published in Communication A 8411 -points 1 to 8-. Please note that on this Institution's website www.bcra.gob.ar, by accessing “Sections - Financial System – LEGAL AND REGULATORY FRAMEWORK – Regulations and summaries – Consolidated texts of general regulations”, you will find the modifications made with text highlighted in special characters (strikethrough and bold). We remain at your service.

-2- We remain at your service. CENTRAL BANK OF THE ARGENTINE REPUBLIC Rubén D. Narduzzi Néstor D. Robledo Chief Manager of Contencious Affairs General Deputy Manager of Compliance and Control ANNEX

2.2.1.2. The Infringement Catalog of Section 11 establishes the maximum number of Sanction Units applicable to each of the infringements detailed therein, depending on the type of entity or subject covered by the BCRA's sanctioning authority. For these purposes, two groups of entities and subjects covered by the BCRA's sanctioning authority are distinguished in the table. Group A consists of financial entities, electronic clearing houses, administrators of electronic fund transfer payment schemes, PSPs subject to registration with the BCRA, and systemically important financial market infrastructures, as well as their external auditors, and representations of foreign financial entities. It also includes other subjects, including those in Group B, that incur infringements under Articles 19 and 38 of the Financial Entities Law (LEF). Group B consists of foreign exchange entities, their external auditors, and other subjects covered by specific BCRA regulations, without prejudice to cases where, due to the nature of the alleged infringement, they are included in Group A under the terms of the preceding paragraph. 2.2.1.3. In cases where benefits derived from the infringement can be quantified or estimated, fines of 1 (one) to 5 (five) times the amount of said benefits will be imposed, provided they exceed the fines resulting from applying the scale set forth in point 2.2.1.1. 2.2.1.4. In the case of very high and high severity infringements, the Board may, upon request by the Superintendent of Financial and Foreign Exchange Entities, additionally order the revocation of operating authorization for subjects authorized by the BCRA. 2.2.2. Natural persons. 2.2.2.1. Regardless of the sanction that may correspond to the infringing legal entity, the sanctions set forth in points 2.1 to 2.3 will be imposed on natural persons found responsible for the infringements through action or omission. In the case of low and minimum severity infringements, natural persons may only be sanctioned in cases evidencing an active or passive non-compliance policy or in cases of repeated infringements or recidivism. 2.2.2.2. In the case of very high severity infringements, disqualification of natural persons will additionally be ordered under Article 41, paragraph 5° of the LEF and Article 5° of Law 18.924, permanently or temporarily (in the latter case for a period not exceeding six (6) years). Disqualification of sanctioned natural persons due to very high severity infringements may only be exempted for duly justified reasons. B.C.R.A. DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359) Section 2. Financial Proceedings. Resolution Stage. Sanctions. Version: 5th COMMUNICATION “A” 8415 Validity: 21/03/2026 Page 2

2.2.2.3. In the case of high and medium severity infringements, disqualification of natural persons may additionally be ordered under Article 41, paragraph 5° of the LEF and Article 5° of Law 18.924, permanently or temporarily (in the latter case for a period not exceeding six (6) years). 2.2.2.4. The disqualification of natural persons under Article 41, paragraph 5° of the LEF and Article 5° of Law 18.924 may be ordered to perform or hold all or some of the positions and/or functions and/or qualifications mentioned in the regulation. Without prejudice to simultaneous disqualification for performing all or some of the remaining positions and/or functions and/or qualifications, disqualification to be a partner or shareholder –applying the aforementioned articles- will only be ordered in the following cases: a) when all or some of the infringements are classified as very high severity and the respondent has prior records under point 2.5.1 for non-compliances classified by this regulation with the same severity; and/or b) when the Superintendent of Financial and Foreign Exchange Entities proposes to the BCRA Board the revocation of operating authorization for the entity regarding which they were a partner or shareholder; and/or c) when it involves unauthorized financial intermediation. 2.3. Graduation of fine sanctions. Without prejudice to other circumstances that may result from considering each specific case, for the purpose of determining the amount of fine sanctions within the corresponding scale, the conclusion report from BCRA preventive areas suggesting the opening of summary proceedings will individualize the infringement according to the catalog in Section 11. or, if applicable, provide a reasoned explanation for classifying an uncataloged regulatory non-compliance or the similarity of the infringing conduct with one of those provided therein. A reasoned and merely provisional score from 1 to 5 will also be assigned to the infringement, taking into consideration the weighting factors contemplated in sections 2.3.1. and 2.3.2. below. 2.3.1. Weighting factors contemplated in Article 41 of the LEF. 2.3.1.1. Magnitude of the infringement. For these purposes, (i) quantity and total amount of infringing operations if they are facts susceptible to monetary appreciation; (ii) number of infringing charges; (iii) relevance of the violated norms within the regulatory system governing the activity, valuing subsequent repeal of the violated norm as a mitigating factor; (iv) duration of the infringing period and (v) impact on the entity and/or financial system. B.C.R.A. DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359) Section 2. Financial Proceedings. Resolution Stage. Sanctions. Version: 5th COMMUNICATION “A” 8415 Validity: 21/03/2026 Page 3

Infringement	Severity	Maximum Fine Group A (in Sanction Units)	Maximum Fine Group B (in Sanction Units)
11.1. Marginality.
11.1.1. Marginal fund collection on a habitual basis within authorized entities.	Very high	800	N/A
11.1.2. Performance of operations involving habitual intermediation between supply and demand of financial resources without prior BCRA authorization.	Very high	800	N/A
11.1.3. Lack of registration of foreign exchange operations by BCRA-authorized entities.	Very high	800	400
11.1.4. Significant shortages or surpluses of securities detected during a BCRA cash count.	High	300	150
11.2. Prohibited and limited operations.
11.2.1. Performance of operations not permitted for each class of entity and exceeding BCRA authorization, not covered in other points.	Very high	500	250
11.2.2. Acceptance of their own shares as collateral by financial entities.	High	300	N/A
11.2.3. Activity in a location prohibited by applicable regulations.	High	200	100
11.2.4. Constitution of liens on assets without BCRA authorization as referenced in the Consolidated Text (TO) on Asset Allocation as Collateral.	High	300	N/A
B.C.R.A.
DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359)
Section 11. Financial Proceedings. Infringement Catalog.
Version: 5th COMMUNICATION “A” 8415 Validity:
21/03/2026 Page 1

| 11.8. Regulations on external control and/or audit. | Severity | Max Fine Group A | Max Fine Group B | | 11.8.1. Absence of relevant working papers regarding internal control and external audit reports. | High | 150 | 75 | | 11.8.2. Irregularities or non-compliances detected and not included or mentioned in external audit reports. | High | 150 | 75 | | 11.8.3. External audit procedures not performed or performed deficiently on significant aspects. | High | 150 | 75 | | 11.8.4. Other non-compliances with minimum external audit regulations not covered in other points. | Medium | 60 | 30 | | 11.9. Regulations on internal control, internal audit and risk management. | Severity | Max Fine Group A | Max Fine Group B | | 11.9.1. Absence of relevant working papers regarding internal control and internal audit reports. | High | 150 | 75 | | 11.9.2. Irregularities detected and not included or mentioned in internal audit reports. | High | 150 | 75 | | 11.9.3. Internal audit procedures not performed or performed deficiently on significant aspects. | High | 150 | 75 | | 11.9.4. Management and/or internal control flaws or weaknesses. | High | 300 | 75 | | 11.9.5. Audit Committee tasks not performed or performed deficiently. | High | 150 | N/A | | 11.9.6. Other non-compliances with minimum internal control and audit system regulations not covered in other points. | Medium | 60 | 30 | B.C.R.A. DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359) Section 11. Financial Proceedings. Infringement Catalog. Version: 5th COMMUNICATION “A” 8415 Validity: 21/03/2026 Page 5

| 11.14.4. Other non-compliances with the TO on Protection of Financial Service Users. | Medium | 70 | 35 | | 11.14.5. Non-observance of provisions contained in the TO on Savings Deposits, Salary Accounts and Special Accounts. | Medium | 70 | N/A | | 11.15. Non-compliance with minimum requirements for managing and controlling technology and information security risks, and with minimum requirements for managing and controlling technology and information security risks associated with digital financial services. | Severity | Max Fine Group A | Max Fine Group B | | 11.15.1. Technology and information security governance. | High | 200 | 100 | | 11.15.2. Technology and information security risk management. | High | 100 | 50 | | 11.15.3. Information technology management. | High | 150 | 75 | | 11.15.4. Information security management. | High | 150 | 75 | | 11.15.5. Business continuity management. | High | 150 | 75 | | 11.15.6. Technological infrastructure and processing. | Medium | 70 | 35 | | 11.15.7. Cyberincident management. | Medium | 70 | 35 | | 11.15.8. Software development, acquisition and maintenance. | High | 100 | 50 | | 11.15.9. Third-party relationship management. | Medium | 60 | 30 | | 11.15.10. Digital financial services. | Very high | 400 | 200 | B.C.R.A. DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359) Section 11. Financial Proceedings. Infringement Catalog. Version: 5th COMMUNICATION “A” 8415 Validity: 21/03/2026 Page 8

| 11.23. National Payment System (NPS). | Severity | Max Fine Group A | Max Fine Group B | | 11.23.1. Non-compliance with the definition and implementation of operational, technical and commercial rules of the payment scheme administered in accordance with the regulatory framework and execution of actions to ensure compliance, including definition and application of fines to incentivize compliance by all participants. | Very high | 800 | N/A | | 11.23.2. Non-compliances with provisions on interoperability. | Very high | 800 | N/A | | 11.23.3. Non-compliances with mandatory homologation and/or technological integration requirements, carried out by administrators of electronic fund transfer payment schemes. | High | 400 | N/A | | 11.23.4. Non-compliances with provisions on service availability. | Very high | 800 | N/A | | 11.23.5. Non-compliances with provisions on limits in different types of immediate transfers. | High | 300 | N/A | | 11.23.6. Non-compliances with provisions on prices and interchange rates. | Very high | 500 | N/A | | 11.23.7. Non-compliances with provisions on settlement/crediting periods. | Very high | 500 | N/A | | 11.23.8. Non-compliances with provisions on courier services. | High | 300 | N/A | | 11.23.9. Non-compliances with provisions on consent. | Very high | 800 | N/A | B.C.R.A. DISCIPLINARY REGIME OF THE CENTRAL BANK OF THE ARGENTINE REPUBLIC (LAWS 21.526 AND 25.065) AND PROCESSING OF FOREIGN EXCHANGE PROCEEDINGS (LAW 19.359) Section 11. Financial Proceedings. Infringement Catalog. Version: 4th COMMUNICATION “A” 8415 Validity: 21/03/2026 Page 11

| 11.23.10. Other non-compliances with the TO on NPS – Transfers. | Medium | 200 | N/A | | 11.23.11. Other non-compliances with the TO on NPS – Transfers – complementary regulations. | Medium | 200 | N/A | | 11.23.12. Other non-compliances with the TO on NPS – Payment Services. | High | 400 | N/A | | 11.23.13. Other non-compliances with the TO on NPS – Immediate Debit. | Low | 100 | N/A | | 11.23.14. Other non-compliances with the TO on NPS – Direct Debit. | Low | 100 | N/A | | 11.23.15. Other non-compliances with the TO on NPS – Electronic Clearing Houses. | High | 500 | N/A | |