Uruguay Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Central Bank of Uruguay Sammy, National Directorate of Free Trade Zones, Ministry of Economy and Finance, Communication Regulatory Agency, Energy and Water Regulatory Agency
Primary Legislation: e.g., banking law, e.g., Communication 2022/247, and further decrees implementing Law 19,996, Ley de Regulación de Activos Virtuales - Virtual Assets Regulation Law, You can typically find this law on the Uruguayan Parliament's website or the Off, This link points to the official publication from December 2021, which was later signed into law, Ley de Mercado de Valores - Securities Market Law, No specific law, decree, or regulation specifically addressing cryptocurrencies,, Customs-related licensing and regulation, governed by the DNA under the Ministry
Travel Rule: Not adopted

Key Facts

aml Ley N° 19.574 (Integral Law Against Money Laundering and Terrorism Financing), dated December 20, 2017: This is the cornerstone legislation that established the general AML/CFT regime, identified obligated subjects, and set out the core requirements for prevention, detection, and punishment of money laundering and terrorism financing. Decreto N° 379/020 (Regulation of Non-Financial Obligated Subjects and Activities Regulated by Law N° 19.574), dated December 23, 2020: This crucial decree explicitly includes "providers of virtual asset services" (proveedores de servicios de activos virtuales) as obligated subjects (sujetos obligados) under the AML/CFT framework. This brought VASPs directly under the regulatory scope, requiring them to comply with the same AML/CFT obligations as traditional financial institutions and other designated non-financial businesses and professions (DNFBPs). Exchange between virtual assets and fiat currencies. Exchange between one or more forms of virtual assets. Transfer of virtual assets. Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets. Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset. For Individuals: Obtain and verify the client's full name, date of birth, nationality, identification number (e.g., national ID, passport), address, and other relevant contact details.
enforcement Issuing warnings and general guidance: Advising the public on risks and clarifying that virtual assets are not legal tender. Developing a regulatory framework: The BCU presented a preliminary proposal for regulating Virtual Asset Service Providers (VASPs) in 2021, and work is ongoing. Applying existing AML/CFT rules: Emphasizing that entities dealing with virtual assets are subject to existing anti-money laundering and counter-terrorist financing (AML/CFT) regulations, even without specific crypto legislation. Regulator Name: Banco Central del Uruguay (BCU) Entity Targeted: All financial institutions, virtual asset service providers (VASPs), and the general public operating in the virtual asset space. Violation Type: Primarily aimed at preventing non-compliance with existing AML/CFT regulations and consumer protection issues arising from unregulated activities. Penalty Amount: Not applicable for a general communication. Date: Issued November 29, 2021 (and subsequent communications). Outcome: Established the BCU's initial position on virtual assets, clarified that they are not legal tender, warned about risks, and reiterated that existing AML/CFT obligations apply to entities dealing with VAs. It also announced the start of a regulatory framework development process. This communication serves as a foundational "warning" and "guidance" for the market. Significance: This is the most significant official statement from the BCU regarding virtual assets, informing the market of its stance and future direction. Any future enforcement would directly reference these principles.
licensing BCU Stance: The BCU has issued communications clarifying its position. While it acknowledges virtual assets, it has explicitly stated that they are not considered legal tender in Uruguay and virtual asset activities generally do not fall under the traditional financial intermediation framework (e.g., banking law) unless they involve activities that would traditionally require BCU authorization (e.g., taking public deposits, issuing e-money as a payment institution). The BCU monitors the sector and indicates the possibility of future, more specific regulation. UIAF Role: The UIAF is the key authority for AML/CFT oversight of VASPs. VASPs are required to register with the UIAF and comply with AML/CFT regulations. Requirement: Registration with the UIAF is mandatory for virtual asset exchanges operating in Uruguay. They are considered "obligated subjects" under AML/CFT law. Nature: This is an AML/CFT registration, not a financial license from the BCU to operate an exchange per se. BCU Consideration: If an exchange offers services that cross into traditional financial activities (e.g., offering interest-bearing accounts in fiat, acting as a payment institution for fiat, issuing regulated financial instruments), it would likely require specific authorization from the BCU in addition to UIAF registration. Nature: Similar to exchanges, this is an AML/CFT registration. BCU Consideration: Purely virtual asset custody is not currently under BCU licensing. However, if the custody provider also offers regulated financial services or manages client funds in a way that falls under existing financial laws, BCU authorization would be required. Requirement: Likely fall under the VASP definition and require registration with the UIAF for AML/CFT purposes.
sanctions Anti-Money Laundering Secretariat (AMLS) – responsible for AML/CFT oversight. Financial Intelligence Unit (UIAF) – part of the Central Bank of Uruguay, monitors financial transactions and STR reporting. Governmental Agency: Law 19,355 enhances AMLS powers. Law 19,355, enacted December 2015, strengthens AMLS supervisory authority over DNFBPs. FATF Membership: Uruguay adheres to FATF standards as a member of GAFILAT (Financial Action Task Force of Latin America). Member of the Financial Action Task Force (FATF) and GAFILAT, committing to global AML/CFT frameworks. Compliance through reporting suspicious activities to the UIAF. No formal application process for licensing; oversight is administrative and based on classification by AMLS.
securities No dedicated VASP licensing regime is in force as of January 2025. Uruguay does not yet have a specific securities law for cryptocurrencies or digital assets. However, the characterization of a "legal vacuum" is misleading: general corporate law, financial intermediation rules, AML/CFT obligations (Ley 19.574), consumer protection statutes, and tax laws (IRAE, IVA) all apply to crypto businesses operating in Uruguay. Draft legislation is advancing. Bill No. 20.345 (2023), "Marco Regulatorio para Proveedores de Servicios de Activos Virtuales" (Regulatory Framework for Virtual Asset Service Providers), was submitted to Parliament in August 2023 and passed the Senate in December 2023. As of January 2025, it awaits Chamber of Deputies approval. The bill would create a VASP license under BCU supervision, impose capital requirements, and align Uruguay with FATF Recommendation 15. BCU regulatory sandbox is operational. Since 2022, the Banco Central del Uruguay (BCU) has run a fintech sandbox (Circular 2.418/2022) that admits crypto-related pilots. Several firms have tested custody, trading, and payment use cases under BCU supervision. FATF status: Uruguay has been a FATF member since October 2018. Its 4th Round Mutual Evaluation Report (MER) was published in September 2021. The MER rated Uruguay "Compliant" or "Largely Compliant" on 36 of 40 Recommendations but flagged gaps in VASP supervision (R.15) and beneficial ownership transparency — gaps that Bill 20.345 aims to close. Regulatory authorities: BCU (prudential, monetary, sandbox, AML/CFT supervision of financial entities), Superintendencia de Servicios Financieros (SSF) (supervision of non-bank financial intermediaries), Ministerio de Economía y Finanzas (MEF) (policy, tax via DGI), and Unidad de Información y Análisis Financiero (UIAF) (financial intelligence unit for STR receipt). Practical pathway today: Entities can incorporate as a Sociedad Anónima (SA) or Sociedad de Responsabilidad Limitada (SRL), register with the Registro Nacional de Comercio, obtain BCU authorization if conducting "financial intermediation" (broadly defined), comply with AML/CFT obligations under Ley 19.574 and BCU Circulares (e.g., 2.350, 2.418), and apply for the sandbox if testing novel models. A dedicated VASP license is expected once Law 20.345 is enacted and BCU issues implementing regulations. Registered up to US$1,786,138,700 in debt securities/warrants on a delayed/continuous basis (Release Nos. 33-6240, 33-6424). Named Banco Central del Uruguay as Fiscal Agent.
status Uruguay permits cryptocurrency and digital asset activity, though it lacks a comprehensive, dedicated statutory framework specifically governing these assets; the existing legal system treats foreign and national investments equally, and most investments are allowed without prior authorization, which extends to digital asset businesses Uruguay - United States Department of State The primary regulatory authorities with jurisdiction over financial and customs matters include the National Customs Directorate (Dirección Nacional de Aduanas, DNA), operating under the Ministry of Economy and Finance, which controls import/export transactions and customs regulations, though no specific cryptocurrency licensing authority has been publicly designated Uruguay - Customs Regulations The National Customs Directorate (Dirección Nacional de Aduanas, DNA) is the primary customs authority, applying, collecting, and controlling taxes under Uruguay's customs code; it operates under the Ministry of Economy and Finance and establishes customs regulations and controls import and export transactions Uruguay - Customs Regulations The DNA's contact information is: Rambla 25 de Agosto 199, Tel.: 2 915 00 07, email: info@aduanas.gub.uy, website: https://www.aduanas.gub.uy/ Uruguay - Customs Regulations Uruguay XXI is the country's export and investment promotion agency, providing information on Uruguay's business climate and investment incentives at national and sectoral levels, and it may serve as a resource for digital asset businesses considering market entry Uruguay - United States Department of State No financial regulator, securities commission, or central bank authority with specific cryptocurrency oversight is named in the source materials, indicating the absence of a designated crypto regulator in the public record as of 2025–2026 Uruguay - United States Department of State Uruguay's customs legislation is governed by the new customs code (CAROU), which entered into force in March 2015 and amends the country's customs legislation to bring it into line with the Mercosur customs code (CAM) Uruguay - Customs Regulations The Mercosur customs code was approved in 2010 and entered into force January 1, 2012, serving as the basis for Uruguay's CAROU Uruguay - Customs Regulations

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile