Asset tokenization in Uruguay: Law 20.345, the Central Bank and the trust

The framework: Law 20.345, BCU and SSF

Law 20.345 brought virtual assets into the perimeter of the Central Bank of Uruguay: virtual asset service providers (PSAV) became financial-system entities supervised by the Financial Services Superintendence (SSF), except those providing only buy-and-sell services, which were subject to anti-money-laundering control alone. Law 20.446 (article 693, in force since January 1, 2026) removed that distinction, and BCU Circular 2507 of July 16, 2026, requires every PSAV to obtain prior authorization from the SSF, with anti-money-laundering and user-protection duties. Status as of November 1, 2026: applications have been accepted since September 1, 2026; platforms that were already operating have until March 31, 2027, to apply and may keep operating while their application is processed, and no PSAV appears yet on the BCU list of virtual asset service providers. Virtual assets that are securities — the case of almost all investment tokenization — are governed by Law 18.627 on the securities market and the same SSF: issuer registration, investor information and, if there is a public offering, its requirements.

The vehicle: the Uruguayan trust

Law 17.703 on trusts governs, among others, financial trusts that issue securities backed by the trust estate, with professional trustees registered with the BCU. It is the Uruguayan variant of the Latin American fideicomiso and the natural vehicle for representing the trust's participation certificates or debt securities in tokens.

What is being tokenized

Real estate (Montevideo and Punta del Este attract regional capital), agriculture and livestock — Uruguay exports cattle traceability and tokenizing farm income fits naturally — and mid-size corporate debt. The reading for an issuer: the country offers framework, trustee and local institutional investors; what it demands is doing it to public-offering standards from day one.

If the project is real estate and you want to raise money from many investors, the country also has a crowdfunding regime with its own caps: we compare them in real estate crowdfunding in Latin America.

How we work with issuers in the country

The anatomy does not change from country to country: classification of the asset, a vehicle with segregated assets, a token with transfer restrictions, verified identity on every transfer and serious custody — the seven-layer platform we build, with the local legal layer on top and a local counsel alongside. The full map of the region is in tokenization in Latin America.

Framework described as of mid-2026 and reviewed as of November 1, 2026, for the authorization of virtual asset service providers; regimes change — check the current status before structuring. Project in Uruguay? Talk to us.