On August 7, 2025, the Central Bank of the Argentine Republic (“BCRA”) issued Communication “A” 8299 (the “Communication”), through which it introduced substantial amendments to the Regulation of Current Bank Accounts and to the Consolidated Text on Savings Deposits, Payroll Accounts, and Special Accounts. Among the most relevant changes, the Communication incorporated the U.S. dollar as an accepted currency to operate current accounts within the Argentine financial system, establishing that checks issued in dollars may only be drawn through electronic means, that is, through the electronic check system (“ECHEQ”).
Among the changes, we can distinguish:
Current Accounts
Regarding current accounts denominated in dollars, authorization to make overdraft withdrawals will be subject to the rules in force concerning Credit Policy. The cancellation of these overdrafts must be made exclusively with U.S. dollar funds freely available to the client, thus ensuring monetary equivalence in the operation.
On the other hand, the Communication imposes on financial institutions the obligation to have a procedural manual regulating the conditions for opening, operating, and closing current accounts. This manual must be based on objective criteria and must prevent any preferential treatment towards related persons or companies. It must also contemplate special procedures for cases of operational discontinuity, where it is not feasible to apply due diligence in accordance with the regulations in force on anti-money laundering, terrorist financing, and other illicit activities. The approval and any modification of the manual must be authorized by the Board of Directors or equivalent authority, following an analysis by the Audit Committee, and such approvals must be recorded in minutes.
Regarding the use of checks, current accounts must allow this modality, except for those opened in the name of legal entities, where the use of checks will be optional. It is established that checks must be drafted in the national language and signed by hand or through authorized alternative means, with a maximum of three signatures per check. Specifically, checks issued in dollars may only be issued through the ECHEQ system.
Additionally, financial institutions are responsible for thoroughly identifying the holders and persons authorized to operate the accounts, recording information such as full name, date and place of birth, marital status, profession or main activity, as well as both actual and special addresses, the latter being mandatory within Argentine territory and unique in cases of accounts with multiple holders. For legal entities, electronic submission of the registered constitutive instrument and the CUIT certificate, obtained directly from the AFIP web portal, will be required, with the account becoming operative on the next banking business day after submission of these documents. In the case of Temporary Business Unions, accounts must be in the name of all participating companies and to the order of the legal representative, accompanied by complete documentation.
Furthermore, internal rules are established aimed at preventing the use of accounts for illicit activities, with special attention to ensuring that transactions are reasonable and compatible with the activity declared by the client. Likewise, institutions must keep records proving that the client was informed about fees and expenses related to the account operation and must make available for consultation the Check Law and applicable regulations, which will also be available on the official BCRA website.
Regarding the management of ECHEQ, holders must adequately safeguard the agreed security elements, preventing their use by unauthorized persons or under inappropriate conditions. Electronic checks must be issued, managed, and deposited following the agreed procedures and security mechanisms, which financial institutions may not disregard when used correctly. In the event that deferred payment checks are traded on stock markets, institutions may provide data related to such operations, being released from confidentiality obligations according to current legislation.
Finally, the Communication establishes transitional provisions requiring financial institutions to ensure that, at all ATMs enabled and operated in the country, both individuals and legal entities can make daily withdrawals of up to ARS 60,000 in a single transaction, without distinction between clients and non-clients, regardless of the account type and the ATM network used. Additionally, requirements are incorporated within the due diligence process according to the OECD Standard for the Automatic Exchange of Information on financial accounts, requiring declarable clients to submit sworn declarations for new accounts opened since April 2022 and for pre-existing accounts since June 2022.
Savings Deposits, Payroll Accounts, and Special Accounts
Several key measures are established for savings deposits, payroll accounts, and special accounts. First, credits corresponding to the exceptional supplement for flood victims must be identified in statements or receipts with the legend “EF – SUP.EXCEPCIONAL” during the benefit period, in compliance with Decree 390/13.
Moreover, financial institutions must ensure that all ATMs in the country allow daily withdrawals of up to sixty thousand pesos in a single operation, without distinction between clients or non-clients and regardless of the account type or ATM network.
Regarding due diligence under the OECD Standard for Automatic Exchange of Information, institutions must request declarable clients to submit sworn declarations for new accounts opened since April 2022 and for pre-existing accounts since June 2022.
Finally, institutions with demand deposit accounts that admit check deposits have until December 1, 2025, to implement, either by their own means or through third parties, the mechanisms that allow their clients to deposit electronic checks in U.S. dollars.
This provision will take effect as of December 1, 2025, the deadline for financial institutions operating accounts that accept check deposits to implement, either by their own means or through third parties, the necessary mechanisms for their clients to deposit ECHEQ issued in U.S. dollars.
