Circular RUNOR 1-1908: Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Foreign Exchange Proceedings (Law 19.359). Amendments.

“Year of the Reconstruction of the Argentine Nation” COMMUNICATION “A” 8278 11/07/2025 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 PAYMENT SERVICE PROVIDERS, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO PEER-TO-PEER CREDIT SERVICE PROVIDERS THROUGH PLATFORMS, TO VALUE TRANSPORT COMPANIES: Ref.: Circular RUNOR 1-1908: Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Foreign Exchange Proceedings (Law 19.359). Amendments.

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We address you to inform you that this Institution has adopted the resolution which, in its relevant part, provides: “1. Substitute point 1.1.1 of Section 1 of the consolidated text on the Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Foreign Exchange Proceedings (Law 19.359) with the following: “1.1.1. Scope of application. This procedure applies to the proceedings that the Central Bank of the Argentine Republic (BCRA) processes in accordance with Article 41 of the Financial Entities Law (LEF) for: 1.1.1.1. Legal and natural persons subject to the scope of application of the aforementioned law and/or covered by its provisions, including those regarding which it has been decided to extend their terms, in accordance with Article 3 of the LEF. 1.1.1.2. Natural persons eventually responsible for the violations that are the subject of the proceedings. 1.1.1.3. Offenders against the provisions of Articles 19 and 38 of the LEF.

-2- 1.1.1.4. Legal and natural persons eventually responsible for violations of the resolutions issued by the BCRA in the exercise of its powers.” 2. Incorporate as new Section 10 of the consolidated text on the Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Foreign Exchange Proceedings (Law 19.359), renumbering the following Sections, the title Voluntary Compliance Agreements in Financial Violations (AC), containing the following: “With the objective of implementing a timely and effective action regarding presumed non-compliance in financial matters, which enables economizing and optimizing the resources of this Institution and the entities and subjects involved in the investigated facts, the prompt regularization of anomalous situations, and a quick and adequate repair of eventual damages to the system and other affected parties, presumed responsible parties may adhere to a proposal from the BCRA for a Voluntary Compliance Agreement in Financial Violations (AC). To this end, the preventive areas, where applicable, must include in the report by which they forward the proceedings to the Financial Contested Affairs Management a proposal that specifies the formal conditions that would enable an agreement, the corrective actions that should be carried out by the subjects under investigation, and the deadlines for compliance, taking into account the following: 10.1. Scope of application. Adherence to the AC proposal will be viable in cases where total or partial non-compliance is detected by legal and natural persons susceptible to being subjected to proceedings under Article 41 of Law 21.526, according to the following conditions: 10.2. Guidelines of the agreement. 10.2.1. To determine the viability of formulating an AC proposal, at least the following issues will be considered: a) That the relevant facts and circumstances in each case are determined. b) In the case of legal persons, that all findings and non-compliances have been or are being remedied to the satisfaction of the BCRA. c) The nature and quality of the subject offender’s commitment to the BCRA during an investigation. d) The absence of new risks for third parties. e) Whether the agreement will contribute to the efficient, effective, and economical use of resources and to the minimization of costs of an eventual sanctioning process. f) The repair within a period not exceeding 36 (thirty-six) months of the damages determined effectively or estimated at the time of deciding on the proposal. 10.2.2. Adherence to the AC must include at minimum the following conditions:

-3- a) Full acknowledgment of the facts. b) Acceptance of the applicable regulatory framework for the non-compliances. c) Written agreement with the proposed sanctions. d) In the case of legal persons, having complied or being in a position to commit to corrective actions that imply improving the entity’s policies and procedures, and, where applicable, promoting internal investigations as appropriate. e) The appearance and consent of the investigated or processed parties who adhere to the proposal. f) In case of quantifiable damages to third parties or the BCRA, their repair. This does not preclude eventual claims that private parties may make. g) The publication of a summary of the agreement on the BCRA website. h) Express conformity with all terms and conditions established in this section. The adherence proposal will contain all the relevant terms, including the corresponding sanctions –if applicable, the calculation of compensations to be paid and the disqualification period– and the deadline to rectify the identified deficiencies, where applicable. 10.3. Benefits for those who adhere to the AC: 10.3.1. Reduction of 30% (thirty percent) to 50% (fifty percent) of the fine according to the table included in this section and/or up to 1/3 (one third) of the disqualification period that would have applied, according to the guidelines established in Section 2. For fine calculation purposes, the midpoint of the scales provided in point 2.3.4 of the aforementioned Section will be used. For estimating the hypothetical fine amount, in the pre-proceedings stage, the qualification, severity, and score of the non-compliance(s) indicated by the preventive area in sending the proceedings to the Financial Contested Affairs Management will be used, while in the proceedings stage, what is established in the charges report, which is an integral part of the resolution ordering the start of the proceedings, will be used.

Procedural Opportunity	Percentage reduction of the presumed fine
a. Prior to the opening of proceedings	50%
b. After the opening of proceedings and before the submission of defenses.	40%
c. After the submission of defenses and before the ruling to open evidence or rejection of offered evidence.	30%

-4- In cases where the benefit derived from the violation can be quantified, the fine amount for legal persons, after the discounts mentioned in the preceding table, may not be less than 1.5 (one point five) times the obtained benefit. 10.3.2. Non-consideration of antecedents for computing recidivism and/or repetition, nor as a proceedings antecedent, provided that no new violation is committed within 5 (five) years from the date of AC homologation. 10.4. Inadmissibility of the agreement. The possibility of proposing the signing of an AC is barred in the following cases: a) When regulated and unregulated subjects are charged for operating without authorization or marginally (violations of Articles 7 and 38 of the Financial Entities Law). b) When, in accordance with the nature of the investigated facts and the severity and provisional classification of the violations, whether existing in the pre-proceedings stage or exposed in the report integrating the resolution ordering the opening of proceedings, the investigated facts could lead to the revocation of the authorization to operate, as provided in paragraph 6) of Article 41 of the Financial Entities Law; it concerns violations classified as “Very High” severity in matters of marginality, prohibited and limited operations, accounting registrations, obstruction to supervision tasks, and non-observance of SEFYC instructions; or investigated non-compliances that are not expressly mentioned in Section 11 and possess such severity. c) When among the antecedents of recidivism under point 2.5 or repetition of non-compliances there are persons who have been disqualified under paragraph 5) of Article 41 of the Financial Entities Law, and more than 3 (three) years have not elapsed from the date of their effective compliance. d) When those involved are recurrent under point 2.5 regarding violations classified as “Very High” severity. e) When within the 5 (five) years prior to the date of adherence to the offer, an AC has been non-complied with. 10.5. Procedural opportunity. Adherence to the AC may be made during the pre-proceedings stage or after the resolution determining the opening of proceedings has been issued. 10.5.1. Pre-proceedings stage. Adherence may be made before the opening of proceedings, according to the conclusions of the BCRA’s preventive areas and the records in the proceedings forwarded to the Financial Contested Affairs Management. In the reports by which the preventive areas forward the proceedings to the aforementioned management, the formal conditions enabling the signing and adherence of the AC must be specified, as well as the corrective actions that subjects under investigation must carry out and the deadlines for compliance, where applicable. 10.5.2. Proceedings stage. Adherence may be made during the proceedings stage until the ruling to open evidence or rejection of offered evidence is issued. The resolution ordering the opening of proceedings will indicate, where applicable, the possibility to adhere to the AC regarding the imputed facts. 10.6. Proposal for adherence to the AC. The proposal for adherence to the AC will be made available to the investigated subjects for acceptance within an irrevocable period of 10 (ten) banking business days counted from the notification to all parties charged as responsible for the investigated facts or processed in the cases mentioned in points 10.3.1 a) and b). In the case of point 10.3.1 c), the proposal will be available to the processed parties during the time mentioned therein. During that period, interested parties will have access to the proceedings in their current state. The proposal for adherence to the AC will be notified to those involved as provided in Section 1. 10.7. Adherence and homologation of the proposal. Subjects identified as responsible for the violation must formulate adherence to the proposal. This adherence may be joint or individual insofar as it does not result in a more favorable situation for the remaining non-adhering parties, and must be made clearly, unequivocally, and unconditionally within the deadline mentioned in the first paragraph of point 10.6. Once formalized, an AC that meets the established requirements will be homologated by the Deputy General Manager of Compliance and Control, and this will be notified to interested parties, to the Trust Management for fine collection and repair of damages to the BCRA resulting from the agreement, and to the preventive management for supervision and follow-up of compliance with remediation measures and verification of repair of damages to third parties determined effectively or estimated at the time of deciding on the proposal. Every homologated Agreement will be brought to the knowledge of the Superintendent of Financial Entities and Foreign Exchange.

-6- In case of a counterproposal by those involved regarding what is provided in point 10.2.2 d) and it is not manifestly inadmissible, it may be considered and homologated by the Superintendent of Financial Entities and Foreign Exchange. From adherence to the AC until its homologation and subsequent total compliance or rejection of adherence, all deadlines will be suspended. Supervision and follow-up of remediation measures compliance will proceed through a separate file. 10.8. Payment of the amount fixed in the agreement. The payment of the total fine amount and the corresponding amount for repairs to the BCRA will be made via bank transfer, within 5 (five) banking business days following the date of notification of the homologating resolution. As for payments to third parties, modalities will be established in each case. The payment facilitation regime provided in point 3.2 and subsequent points will not apply, nor will unpaid fines be judicially executed given what is provided in point 10.10. Once the proposal has been fully complied with, proceedings will be archived as pre-proceedings or proceedings, as applicable. 10.9. Non-adherence to the proposal. Lack of homologation. In case of non-adherence to the agreement proposal within the deadline set in the first paragraph of point 10.6 or failure to be homologated, proceedings will continue according to the rules for instructing proceedings for those who did not adhere, depending on whether they are pre-proceedings or proceedings. Subsequent archiving of pre-proceedings or total or partial absolution in administrative or judicial proceedings regarding those who did not adhere to the agreement proposal or failed to comply will not benefit those who did adhere and paid the fine. Terms of a non-homologated proposal in the pre-proceedings stage will in no case condition, limit, or restrict what may be proposed in the proceedings stage regarding the imputations that are finally made, nor can they be pleaded by interested parties for their benefit. Appeals filed against the administrative act rejecting homologation of the proposal will not suspend the continuation of proceedings and their effects. 10.10. Non-compliance with the agreement. In case of non-compliance with the homologated agreement regarding payment of fines and/or effective implementation of agreed remediation measures by legal and/or natural persons, pre-proceedings or proceedings will continue according to their status regarding those who failed to comply with the agreement.

-7- Regarding non-compliance in implementing agreed remediation measures and/or repair of damages, pre-proceedings and/or proceedings will continue according to their status against legal and natural persons responsible for non-compliance with corrective measures, expanding the imputation regarding responsible persons if necessary. In the event that payments have been made, they will not be refundable and will not be considered as credited toward what ultimately corresponds within the framework of an eventual fine. 10.11. Transitional clause: What is provided in this Section will apply to financial proceedings that, on the date of approval of this regulation, are in the stage provided in point 10.5.2., only if expressly requested by the processed party(ies).” 3. Substitute Section 4 of the consolidated text on the Disciplinary Regime of the Central Bank of the Argentine Republic (Laws 21.526 and 25.065) and Foreign Exchange Proceedings (Law 19.359) with the following text: “Section 4. Financial Proceedings. Publication of resolutions and ACs. Resolutions that initiate or conclude summary proceedings processed by the BCRA under Article 41 of the LEF and ACs will be made known on the institutional website. 4.1. Regarding resolutions that conclude summary proceedings, it will be indicated whether they are final or not. 4.2. They will be made known, regardless of whether they are final, by communication addressed to entities covered by the LEF and Law 18.924, as follows: 4.2.1. Revocation of authorization to operate. 4.2.2. Temporary or permanent disqualification from serving as promoters,