Circular 009-2025: Implementation of AML Verification Fees for New PSAD Registration Applications

CIRCULAR-009-2025.

Subject: Implementation of AML verification fees for new PSAD registration applications.

San Salvador Centro, December 2, 2025.

To: Legal Representatives and Attorneys-in-Fact Interested Parties in General Present.

We refer to the recent promulgation and entry into force of the new Special Law for the Prevention, Control, and Sanction of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (hereinafter, "Special Law"). This law incorporates the National Commission of Digital Assets (CNAD) as a member of the Interinstitutional Committee for the Prevention and Control of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (CIPLAFT), and assigns it functions of supervision, inspection, and oversight of Digital Asset Service Providers (PSAD) in this matter, according to its Articles 5, 11, and 12, paragraph 7.

Regarding this matter, the legislator established that supervisory and oversight entities must have adequate structures, specialized human resources, as well as appropriate technical and financial resources to fulfill their functions in the matter of preventing Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (hereinafter AML/CFT). In turn, the Digital Assets Issuance Law (LEAD) establishes that the Commission is the competent authority to apply sectoral regulations, promote a safe and orderly market, and supervise PSADs in accordance with what is provided in Articles 7, 8, and 9, letters a) and k) of the LEAD.

Consequently, in order to reinforce the integrity of the ecosystem and ensure that applicants comply, from the outset, with minimum standards in the matter of AML/CFT prevention, the CNAD has warned of the need to establish an Early AML/CFT Compliance Assessment, as a mandatory step prior to the license application, based on a Risk-Based Approach. This process responds to two essential circumstances: (i) the CNAD has achieved its greatest regulatory advances thanks to the strict protection of the system against AML/CFT risks, and (ii) it has been identified that the main cause for which applicants do not obtain the license is the non-compliance or weakness of their AML/CFT prevention frameworks. Therefore, this early assessment will include the specialized review of internal control, manuals, policies, procedures for the detection and reporting of suspicious and regulated transactions, corporate governance responsibilities, and compliance officer duties, as well as risk management methodologies and the suitability of the technological tools and mechanisms used in their operations.

Calle La Mascota, Building 144, San Salvador District, San Salvador Centro, El Salvador, C.A.- registro@cnad.gob.sv - https://cnad.gob.sv

---

In virtue of all the above, this Commission, based on what is established in Article 11, final paragraph of the Special Law, and Articles 9, letters a), 11, letter h), and 12, final paragraph of the LEAD, the Board of Directors approved through Minute Point No. 13/2025, dated November 18, 2025, the establishment of a fee in the amount of two thousand five hundred United States dollars (US$2,500.00), for the technical review and verification of compliance in the implementation of the risk-based approach, considering the analysis of the AML/CFT prevention framework, the implementation of adequate policies and procedures for the mitigation of related risks, taking into account the technology inherent to the activities they perform. The amount was determined in accordance with the estimated operational cost to carry out the specialized verifications, in a proportional and reasonable manner to the complexity of the sector.

The fee will be enforceable starting December 8, 2025, and must be paid at the time of submitting the application for the Early AML/CFT Compliance Assessment, accrediting it in the current account of this Commission at Banco Agrícola, S.A.

On the other hand, in addition to the above, this Commission is preparing a technical report in order to define supervision tariffs in the matter of AML/CFT during the 2026 fiscal year, which will be applicable only to digital asset service providers, and other obligated subjects that have already been authorized and are supervised by this Commission. This process will include the comprehensive evaluation of the digital asset market risk, reviewing aspects such as due diligence processes, Know Your Customer (KYC), Know Your Business, and Know Your Transaction mechanisms, asset custody mechanisms, record keeping, reports, transactional monitoring, automated alert systems, and other relevant elements of risk management, in order to guarantee compliance with the obligations established in the Special Law.

This analysis will allow establishing a robust methodology for the planning and execution of supervision programs with a risk-based approach, determining the frequency and intensity of supervisory activities according to the particular characteristics of each supervised entity.

We thank you for your attention and reiterate our commitment to efficient, technical supervision aligned with the Special Law, the regulatory framework, and international standards.

Without further particulars,

[Signature] Juan Carlos Reyes García President National Commission of Digital Assets

Calle La Mascota, Building 144, San Salvador District, San Salvador Centro, El Salvador, C.A.- registro@cnad.gob.sv - https://cnad.gob.sv

---

[Signature] César Alejandro Córdova Figueroa Proprietor Director National Commission of Digital Assets

[Signature] Carlos David Aguilar Cerna Proprietor Director National Commission of Digital Assets

Calle La Mascota, Building 144, San Salvador District, San Salvador Centro, El Salvador, C.A.- registro@cnad.gob.sv - https://cnad.gob.sv