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Uruguay
UYschema crypto-v2.0.0trajectory: not yet assessedin transitionoverlaps: FIM, WPM
Last updated · 8 categories · 16 sourced
findings · 13 sources in the cumulative register
8Categoriesbaseline.
16Findings.claims[]
8Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix(sums to 8 rendered categories; click to filter)
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Jurisdiction lead brief
Lead Signal
Uruguay's virtual-asset regulatory architecture has undergone a significant statutory reclassification this cycle. The Interpreter's Challenger-fold process traced the statutory basis for the Banco Central del Uruguay (BCU) and its Superintendencia de Servicios Financieros (SSF) to supervise virtual-asset service providers and, specifically, stablecoin issuers under Article 37 of the BCU's Carta Organica away from Ley N.o 20.345 (19 September 2024) and onto Ley N.o 20.446, the 2025-2029 National Budget Law promulgated 16 December 2025, whose Article 694 re-wrote Article 37 to expressly capture "los emisores de activos virtuales estables" and providers of virtual-asset services more broadly. This is not a cosmetic citation fix: Ley N.o 20.446 appears, per two independently sourced legal-advisory trackers, to have eliminated the differentiated PSAVF/PSAVNF (financial versus non-financial virtual-asset provider) licensing model that had structured BCU/SSF's August 2025 draft implementing regulation, replacing it with a uniform PSAV regulatory mandate. That draft regulation itself is now in a state of flux, requiring BCU/SSF to reformulate its rulemaking to reflect the new budget-law text. A reported revision of the draft, dated 16 March 2026 and said to incorporate new capital, guarantee and deposit thresholds, has not been independently verified. Confidence on the underlying statutory correction sits at Probable rather than Confirmed, pending a second primary-source anchor beyond the IMPO consolidated legislative database, and the overall Uruguay record has moved to an in-transition status: the regulatory perimeter is in force, but the instrument that operationalises it is being rebuilt in real time.
Other Developments
Beneath the headline correction, Uruguay's broader token-classification and consumer-protection picture remains built substantially on non-binding BCU guidance rather than binding rule. BCU's conceptual framework document continues to treat exchange-type assets such as Bitcoin and Ether, and utility-type assets, as falling outside any issuance-authorization requirement, while treating issuers of stable virtual assets as analogous to electronic-money issuers subject to payment-system regulation and as owing holders a redemption right against backing reserves. None of this guidance is binding, and its relationship to the newly corrected statutory perimeter under Ley N.o 20.446 has not yet been tested in a finalized implementing rule. Separately, BCU's non-binding guidance calling on unregistered habitual providers to seek a license now sits alongside a superseded 2022 SSF position -- predating Ley N.o 20.345 -- that had held cryptoasset intermediation to fall outside BCU's regulatory reach; the historical claim is retained as context rather than current law. On the consumer-protection side, the August 2025 draft PSAV regulation's proposal to apply consumer-protection obligations specifically to PSAVF (while limiting PSAVNF obligations to AML/CFT/proliferation-financing) has been downgraded from Probable to Uncertain confidence, because the PSAVF/PSAVNF distinction it depends on may no longer be the operative model following Ley N.o 20.446. BCU's 2021 communique reminding users to evaluate virtual-asset risk exhaustively, and clarifying that financial institutions are not obliged to process virtual-asset transactions, remains a stable, unaffected data point. Three modules -- on-chain activity regime, tax treatment, and cross-border transfer -- continue to register as genuine sourcing gaps rather than settled "no regulation" findings: no BCU, SSF or tax-authority publication was located addressing staking, DeFi, mining, validator or node activity; IRAE/IRPF/IVA treatment of virtual-asset transactions; or a crypto-specific cross-border transfer regime distinct from the general VASP perimeter.
Cross-Monitor Connections
Two overlap signals are carried into this cycle. First, for financial-integrity: the draft PSAV regulation -- itself now of uncertain status following Ley N.o 20.446 -- had proposed applying AML/CFT and proliferation-financing obligations to both PSAVF and PSAVNF categories of provider; this is disclosed here as context for the subscribed aml_cft_regime surface, which is not independently populated with original analysis in this record. Second, for world-payments: BCU's guidance treating stable-virtual-asset issuers as analogous to electronic-money issuers subject to payment-system regulation, combined with the fact that the operative statutory vehicle here is a national budget law with broader implications for BCU's regulatory perimeter, gives this cycle's stablecoin development a direct payments-oversight dimension worth tracking alongside Uruguay's e-money framework.
Outlook
The record is held pending regulator confirmation rather than published outright, because the central open question -- whether BCU/SSF has finalized, or is still drafting, an implementing regulation that reflects Ley N.o 20.446's apparent move to a uniform PSAV mandate -- remains unresolved. The reported 16 March 2026 revised draft sits in a backfill queue awaiting independent verification of its existence, content and finalization status. Also unresolved: the fate of the Anteproyecto de Ley referenced in BCU Directorio Resolution D/248/2025, and whether it was folded into Ley N.o 20.446 or remains a separate pending instrument. Until either is confirmed, Uruguay's licensing, token-classification, stablecoin and consumer-protection modules should be read as describing a regime in active reconstruction rather than a settled baseline, with the next material trigger likely being either a finalized BCU/SSF resolution or independent corroboration of the March 2026 draft's terms.
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Uruguay brought virtual-asset service providers (VASPs) within the Banco Central del Uruguay (BCU) regulatory perimeter via Ley N.º 20.345 (19 September 2024), which amended Article 37 of the BCU's Carta Orgánica (Ley N.º 16.696) to add 'los proveedores de servicios sobre activos virtuales' (literal H) and 'los emisores de activos virtuales estables' (literal C) as entities regulated and supervised by the Superintendencia de Servicios Financieros (SSF). The implementing regulation specifying registration/licensing mechanics — distinguishing Proveedores de Servicios de Activos Virtuales Financieros (PSAVF) from Proveedores de Servicios de Activos Virtuales No Financieros (PSAVNF) — was published for public consultation on 21 August 2025 with comments due by 19 September 2025; its final, in-force text has not been independently confirmed as of the research date. A separate BCU Board proposal (Resolución D/248/2025, 11 August 2025) sent to the Ministry of Economy and Finance seeks further legislative expansion of the regulatory perimeter. Prior to the 2024 law, BCU/SSF explicitly stated that crypto intermediation activity was not regulated by the Central Bank.
Open gap — crypto-int-4Status of the Anteproyecto de Ley referenced in Resolucion D/248/2025 (sent to the Ministry of Economy and Finance) is unconfirmed - unclear whether superseded, incorporated into Ley N.o 20.446, or still pending; research the current legislative status.no under-indexing note recorded
Open gap — crypto-int-5The BCU/SSF's reformulated PSAV draft regulation (reportedly published 16 March 2026 per Challenger flag f-003, incorporating new capital/guarantee/deposit thresholds and Ley N.o 20.446 changes) has not been independently verified or confirmed finalized/in-force; research to confirm its content, status and any subsequent finalization.no under-indexing note recorded
Open gap — crypto-int-6Whether Ley N.o 20.446's move to a uniform PSAV regulatory mandate has been reflected in a finalized BCU/SSF resolution (as opposed to still-draft form) is unconfirmed as of the research date; research the current in-force status of BCU's PSAV implementing regulation.no under-indexing note recorded
Standing sub-brief560 words · last cycle 2026-08-06
Crypto Licensing
Uruguay's crypto licensing perimeter rests on Article 37 of the BCU's Carta Organica (Ley N.o 16.696), which Ley N.o 20.345 first amended on 19 September 2024 to bring providers of virtual-asset services within BCU/SSF regulatory and supervisory reach, replacing what had been, per a 2022 SSF resolution addressing an unauthorized funds-transfer scheme, an explicit position that cryptoasset intermediation activity fell outside BCU's regulatory scope. That 2022 position is retained in this record as historical context, not current law: it predates both Ley N.o 20.345 and the subsequent Ley N.o 20.446, and does not describe the present regime. Following the 2024 amendment, BCU/SSF opened a public consultation in August 2025 on a draft implementing regulation that would have operationalised licensing through two differentiated categories: PSAVF (financial virtual-asset providers) and PSAVNF (non-financial virtual-asset providers), with comments due 19 September 2025. Separately, BCU's non-binding conceptual-framework guidance calls on unregistered habitual providers to apply for a license covering whichever regulated virtual-asset activities they intend to provide -- a statement of policy intent rather than a binding legal requirement, and one for which no formal regulatory_stage is asserted, consistent with its non-normative character.
The most material development this cycle is the identification of Ley N.o 20.446, Uruguay's 2025-2029 National Budget Law, promulgated 16 December 2025. This law's Article 694 re-wrote Article 37 of the Carta Organica, and -- per two independently sourced legal-advisory trackers (Brum Costa Abogados and Posadas, Posadas & Vecino) -- appears to have eliminated the PSAVF/PSAVNF differentiated model underpinning the August 2025 draft regulation, replacing it with a uniform BCU regulatory mandate applicable to providers of virtual-asset services generally. This finding was not present in the original research pass; it was surfaced only through the Challenger fold process and is sourced to T3 legal-advisory material rather than a direct T1 reading of a reformulated BCU draft text, so it carries Probable rather than Confirmed confidence. Its implication, if borne out, is that BCU/SSF must reformulate its implementing regulation to reflect the new statutory architecture -- meaning the August 2025 draft's PSAVF/PSAVNF structure can no longer be treated as the operative blueprint for how licensing will actually be administered. Compounding the uncertainty, a further, independently unconfirmed report describes a revised BCU PSAV draft published 16 March 2026 incorporating new capital, guarantee and deposit thresholds and reflecting the Ley N.o 20.446 changes; this report has not been corroborated and sits in the backfill queue.
Outlook
Uruguay's crypto licensing trajectory is best read as tightening but structurally unsettled: the statutory perimeter is in force and has, if anything, broadened toward a uniform PSAV mandate, but the implementing regulation that would give licensing applicants and existing providers operational clarity is itself being rewritten. The next material development to watch for is either a finalized BCU/SSF resolution reflecting Ley N.o 20.446, or independent confirmation of the reported March 2026 revised draft's content and status. Until one of these resolves, providers operating in or into Uruguay face a licensing framework whose statutory foundation is confirmed but whose administrative detail -- registration categories, capital thresholds, and the PSAVF/PSAVNF question specifically -- remains in motion. The unresolved status of the Anteproyecto de Ley referenced in BCU Directorio Resolution D/248/2025 (sent to the Ministry of Economy and Finance) is a further open thread that could either be subsumed within Ley N.o 20.446 or surface as a separate legislative track.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
T1 · BCU / Superintendencia de Servicios FinancierosBCU / Superintendencia de Servicios Financieros — Ley N.º 20.345 (19 September 2024) amended Article 37 of the BCU Carta Orgánica to bring providers of virtual-asset services within the BCU/SSF regulatory and supervisory perimeter.retrieved M5bindingin force
T1 · BCU / Superintendencia de Servicios FinancierosBCU / Superintendencia de Servicios Financieros — On 21 August 2025, the SSF published a draft implementing regulation for public consultation defining PSAVF (financial virtual-asset providers, e.g. exchange, transfer, custody and administration services) and PSAVNF (non-financial virtual-asset providers), with comments accepted until 19 September 2025.retrieved M4non-binding
T2 · Banco Central del UruguayBanco Central del Uruguay — Under BCU's non-binding conceptual framework guidance, entities not currently registered with BCU that intend to habitually and professionally provide virtual-asset services must apply for a license covering the regulated virtual-asset activities.retrieved M3non-binding
T1 · Superintendencia de Servicios Financieros / BCUSuperintendencia de Servicios Financieros / BCU — Prior to Ley N.º 20.345, the SSF held that cryptoasset intermediation activity was not regulated by the Banco Central del Uruguay, per a 2022 SSF resolution addressing an unauthorized funds-transfer scheme using cryptoassets.retrieved M2non-binding
BCU's non-binding 'Marco conceptual para el tratamiento de Activos Virtuales' categorizes virtual assets by economic substance into: AV de Seguridad (security-like, potentially falling under existing securities law Art. 13 Ley 18.627), AV de Utilidad (utility, no issuance authorization required), AV Estable (stable, treated analogously to electronic-money issuance), and AV de Intercambio (exchange-type, e.g. Bitcoin/Ether, no issuance authorization required). Separately, Ley N.º 20.345 gives binding legal effect to the inclusion of 'emisores de activos virtuales estables' (stablecoin issuers) within the BCU/SSF perimeter.
Standing sub-brief380 words · last cycle 2026-08-06
Token Classification
Uruguay's token classification framework operates on two levels that are not yet fully reconciled. At the guidance level, BCU's non-binding conceptual framework for virtual assets sorts tokens into categories without imposing issuance-authorization requirements on either utility-type virtual assets or exchange-type virtual assets such as Bitcoin and Ether used as a medium of exchange or investment. Stable virtual assets are treated differently within that same guidance: BCU analogises issuers of stable virtual assets to electronic-money issuers, placing them conceptually within the payment-system regulatory framework and recognising holders' rights over backing reserve assets, including a redemption commitment the issuer is expected to honour on request. None of this guidance-level taxonomy is binding law.
At the binding-statute level, this cycle corrects a citation error carried from the original research pass. Article 37 of the BCU's Carta Organica now expressly includes "los emisores de activos virtuales estables" (stablecoin issuers) among the entities the SSF/BCU regulates and supervises -- but the correct statutory source for that language is Ley N.o 20.446 (the 2025-2029 National Budget Law, promulgated 16 December 2025, Article 694), not Ley N.o 20.345 as originally recorded. This correction was applied against IMPO's official consolidated text of Article 37, which is why the effective date attached to this binding classification moved from 19 September 2024 to 16 December 2025, and why confidence was downgraded from Confirmed to Probable pending a second independent T1/T2 source corroborating the IMPO reading. The practical effect is that the single most consequential token-classification claim in Uruguay's regime -- that stablecoin issuers sit inside the regulatory perimeter -- is confirmed as binding and in force, but now rests on a corrected and not-yet-doubly-anchored statutory citation.
Outlook
Watch for two converging threads: first, whether BCU/SSF's reformulation of its implementing regulation (tracked under crypto_licensing) will translate the binding stablecoin-issuer classification into concrete prudential detail -- reserve composition, disclosure, redemption mechanics -- beyond the current non-binding conceptual guidance; and second, whether a second primary-source anchor for the Ley N.o 20.446 Article 37 language emerges to move confidence on the corrected statutory basis back toward Confirmed. Utility-type and exchange-type token treatment appears comparatively settled at the no-authorization-required guidance level, but that stability itself depends on BCU not revisiting its conceptual framework document in light of the broader legislative changes now underway.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (4)
T1 · Banco Central del UruguayBanco Central del Uruguay — Ley N.º 20.345 amended Article 37 of the BCU Carta Orgánica to expressly include 'los emisores de activos virtuales estables' among entities regulated and supervised by the SSF/BCU.retrieved M5bindingin force
T2 · Banco Central del UruguayBanco Central del Uruguay — BCU's conceptual framework treats issuers of stable virtual assets as analogous to electronic-money issuers, subject to the regulatory framework applicable to the payment system.retrieved M3non-binding
T2 · Banco Central del UruguayBanco Central del Uruguay — Under the conceptual framework, issuance of utility-type virtual assets does not require BCU authorization.retrieved M2non-binding
T2 · Banco Central del UruguayBanco Central del Uruguay — The conceptual framework classifies exchange-type virtual assets such as Bitcoin and Ether, used as a medium of exchange or investment, without requiring issuance authorization.retrieved M2non-binding
No BCU or other Uruguayan regulator publication was identified that specifically addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization as discrete regulated on-chain activities. The regulatory perimeter established by Ley N.º 20.345 and the PSAV draft regulation is framed around service-provider intermediation (exchange, transfer, custody, administration) rather than protocol-level on-chain activity categories.
Open gap — crypto-int-1No BCU, SSF, or other Uruguayan regulator publication addresses staking, DeFi lending/DEX operation, mining, node operation, validator activity, or tokenization as discrete on-chain activity categories; research to confirm whether BCU intends to address on-chain activity within the reformulated PSAV framework.DeFi and validator-level on-chain activity is a known under-indexed vector per BIAS CORRECTIONS; assert once a regulator source speaks to it.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · Banco Central del UruguayBanco Central del Uruguay — primary source not yet reachedretrieved M1non-bindingour coverage gap, expected to resolve on a re-run
Ley N.º 20.345 explicitly brought 'emisores de activos virtuales estables' within the BCU/SSF regulatory perimeter (Article 37, literal C, as amended). BCU's non-binding conceptual framework further describes stable-virtual-asset issuers as analogous to electronic-money issuers: holders obtain rights over any backing reserve assets, and the issuer commits to honour redemption requests. No dedicated reserve-requirement, disclosure, or systemic-designation rule specific to stablecoins beyond this e-money analogy was located, and the binding implementing regulation for stablecoin issuers (distinct from the PSAV consultation) was not confirmed as finalized.
Standing sub-brief345 words · last cycle 2026-08-06
Stablecoin Regime
Uruguay's stablecoin regime combines a now-corrected binding statutory perimeter with a body of non-binding prudential guidance. On the binding side, Ley N.o 20.446 (2025-2029 National Budget Law, Article 694, promulgated 16 December 2025) re-wrote Article 37 of the BCU Carta Organica to place issuers of stable virtual assets within the entities the BCU, via the SSF, regulates and controls under Article 37, literal C. This supersedes the wording previously attributed to Ley N.o 20.345 (19 September 2024): the correction was made against IMPO's official consolidated legislative text, shifting the effective date of this binding classification by more than a year, and confidence was downgraded from Confirmed to Probable because the correction currently rests on a single T1 source (IMPO) without a second independent T1/T2 anchor. This is a materially consequential correction because it changes the named legal authority underpinning the entire stablecoin-issuer perimeter, not merely a date.
On the guidance side, BCU's non-binding conceptual framework document sets out that holders of stable virtual assets are understood to have rights over the backing reserve assets, with the issuer expected to make redemption effective upon a user's request. This redemption-right expectation is not itself a binding prudential rule -- there is no confirmed reserve-composition, disclosure, or systemic-designation requirement in force -- and it should be read as BCU's stated policy orientation rather than an enforceable standard pending the reformulated implementing regulation referenced under crypto_licensing.
Outlook
The near-term question for Uruguay's stablecoin regime is whether BCU/SSF's implementing regulation -- now being reformulated following Ley N.o 20.446's elimination of the PSAVF/PSAVNF model -- will convert the binding Article 37 perimeter inclusion and the guidance-level redemption expectation into enforceable prudential requirements (reserve backing ratios, audit or attestation obligations, redemption timelines). Until that reformulated text is confirmed, Uruguay's stablecoin-issuer treatment should be read as: perimeter inclusion is binding and in force, but the operational content of that inclusion remains guidance-level and provisional. The world-payments overlap flagged for this module -- BCU's electronic-money-issuer analogy -- is worth tracking alongside any payments-system-specific rulemaking that might emerge from the same budget-law process.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · Banco Central del UruguayBanco Central del Uruguay — Ley N.º 20.345 places stable-virtual-asset issuers within the entities that the BCU, via the SSF, regulates and controls under Article 37, literal C.retrieved M5bindingin force
T2 · Banco Central del UruguayBanco Central del Uruguay — Under BCU's conceptual framework, holders of stable virtual assets obtain rights over any backing reserve assets and the issuer commits to make redemption effective upon the user's request.retrieved M3non-binding
The August 2025 draft PSAV regulation differentiates the regulatory and supervisory focus by provider type: PSAVF (financial virtual-asset providers) are proposed to be subject to both consumer-protection rules and AML/CFT/proliferation-financing rules, whereas PSAVNF (non-financial virtual-asset providers) are proposed to be subject only to AML/CFT/proliferation-financing rules. Separately, BCU's 2021 public communique issued non-binding risk-disclosure recommendations to users and the general public regarding virtual-asset volatility, custody risk, and counterparty risk, noting financial institutions are not obliged to process virtual-asset transactions.
Standing sub-brief304 words · last cycle 2026-08-06
Consumer Protection
Uruguay's crypto consumer-protection posture combines one stable, long-standing communique with one now-uncertain draft-regulation proposal. BCU's 2021 communique on virtual assets recommended that users evaluate virtual-asset risks exhaustively and clarified that financial institutions are not obliged to process virtual-asset transactions, nor are merchants obliged to accept them as payment. This remains a stable data point, unaffected by subsequent legislative developments and carrying Confirmed confidence.
The more consequential item concerns BCU/SSF's August 2025 draft PSAV implementing regulation, which had proposed a differentiated consumer-protection burden: PSAVF (financial virtual-asset providers) would have been subject to both consumer-protection and AML/CFT/proliferation-financing rules, while PSAVNF (non-financial providers) would have been subject only to the AML/CFT/proliferation-financing rules. This cycle downgrades confidence in that proposal from Probable to Uncertain, because the underlying PSAVF/PSAVNF distinction it depends on may itself have been superseded by Ley N.o 20.446's apparent move toward a uniform BCU regulatory mandate for virtual-asset service providers generally (tracked under crypto_licensing). In other words, it is no longer clear whether PSAVF-specific consumer-protection obligations remain a live proposal, have been folded into a uniform standard applicable to all PSAV, or have lapsed pending the reformulated draft. Both readings are retained in this record as a disclosed conflict rather than resolved in either direction, pending confirmation of BCU/SSF's post-Ley-N.o-20.446 regulatory text.
Outlook
Consumer-protection treatment for Uruguay's virtual-asset sector is presently the most exposed module to the broader licensing-model uncertainty described elsewhere in this record: its central forward-looking claim is explicitly contingent on a regulatory restructuring whose final shape is not yet confirmed. The 2021 BCU communique's baseline consumer-risk messaging is unlikely to change regardless of how the PSAVF/PSAVNF question resolves, but any assessment of provider-level consumer-protection obligations should be treated as provisional until BCU/SSF's reformulated implementing regulation is confirmed and its consumer-protection provisions -- whether uniform or still differentiated -- are identified.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (2)
T1 · Banco Central del UruguayBanco Central del Uruguay — BCU's 2021 public communique recommended users evaluate risks exhaustively when operating with virtual assets and clarified that financial institutions are not obliged to process virtual-asset transactions nor are merchants obliged to accept them as payment.retrieved M2non-binding
T1 · BCU / Superintendencia de Servicios FinancierosBCU / Superintendencia de Servicios Financieros — The draft PSAV regulation proposes that regulatory and supervisory focus for PSAVF include consumer protection, while PSAVNF providers are proposed to be regulated only for AML/CFT/proliferation-financing purposes.retrieved M3non-binding
No crypto-specific tax instrument (IRAE, IRPF, VAT/IVA, withholding, or crypto-specific reporting obligation) issued by Uruguay's Dirección General Impositiva (DGI) or Ministry of Economy and Finance was located during this research pass. Uruguay's general source-based tax system (Uruguayan-source income rules under IRAE/IRPF) would presumptively apply to crypto-derived income under general principles, but no primary source confirming specific application to virtual assets was found.
Open gap — crypto-int-2No DGI or Ministry of Economy and Finance publication confirming IRAE/IRPF/IVA/withholding treatment of virtual-asset transactions or VASP revenue was located; research DGI guidance specifically.tax_treatment is structurally thin across the crypto estate per BIAS CORRECTIONS.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
no periodic updates on record for this sub-brief
Sources and findings (1)
primary source not yet reachedM2non-bindingour coverage gap, expected to resolve on a re-run
No Uruguay-specific crypto cross-border transfer restriction, sanctions nexus rule, reporting threshold, or crypto travel-rule cross-border regime was identified in this research pass. Uruguay generally maintains open capital-account policy, but no primary source was located confirming or denying a crypto-specific cross-border control regime distinct from the general VASP perimeter established by Ley N.º 20.345.
Open gap — crypto-int-3No Uruguay-specific crypto cross-border transfer restriction, sanctions nexus, reporting threshold, or travel-rule cross-border regime distinct from the general VASP perimeter (Ley N.o 20.345/20.446) was identified; research needed to confirm presence or absence of such a regime.cross_border_transfer is structurally thin across the crypto estate per BIAS CORRECTIONS.
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
no periodic updates on record for this sub-brief
Sources and findings (1)
primary source not yet reachedM2non-bindingour coverage gap, expected to resolve on a re-run
Crypto AML/CFT obligations for Uruguay are covered under the shared Financial Integrity Module (FIM) 'aml_ctf' subscription and are intentionally NOT reproduced as claims in this crypto baseline per fleet doctrine. Contextually, the draft PSAV regulation (August 2025 consultation) applies AML/CFT/proliferation-financing obligations to both PSAVF and PSAVNF providers, and Ley N.º 20.345 situates VASPs within the SSF's supervisory perimeter, which historically has included AML/CFT control functions for regulated financial entities.
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