Canada    FinTech Guide    Chapter 6    Uruguay

6. Virtual Currency - Bitcoin
Uruguay  Uruguay

Legal Affairs

There are no regulations in Uruguay which apply to virtual currencies such as bitcoins; however, depending on the services rendered by the service provider, a license may be required under local regulations.

According to Circular 2.198 of the CBU and Law 19.210 (the Financial Inclusion Law), issuers of electronic money (“dinero electrónico”) have to register before the CBU as Issuers of Electronic Money. Electronic money is defined under Law 19.210 as the different instruments representative of a monetary value which are demandable to its issuer, such as pre-paid cards, electronic wallets and other analog instruments, and need to comply with certain characteristics (e.g.: cash out can be done at any time; virtual currency can be used to cancel obligations with third parties, etc.). These entities may only have as their exclusive purpose issuing this type of currency and are subject to the control of the CBU. In order to register as such they need to submit certain information listed in CBU’s regulations which refer to the entity, the economic group, the shareholders, the superior personnel, the systems used, the bank accounts to be used, etc.

Also, as mentioned under “1. / Uruguay / Legal affairs”, there is a different license which applies to those entities which provide payment services and ancillary services (but the main difference with the prior one is that they do not create “electronic money” in the terms of law 19.210). As to this type of license please refer to “1. / Uruguay / Legal affairs”.

In both cases no costs are involved for registering or obtaining the license, there are no legally required running costs nor financial reserves required.

Economic Conditions

No data available.


Our Government has taken a particular interest in regulating and promoting FinTech and different technological projects in the country regarding finance, through modern regulations and legislation, specifically through dispositions and regulations of the CBU and national laws. Such actions are planned to continue in the present year and in the near future.

Please note that no example of virtual currency services have been approved in Uruguay up to date. If the CBU decides to regulate virtual currencies, such as bitcoins, it may understand that the same are a type of security and therefore the entity providing these type of currencies may be required to obtain the license of broker dealer (referred to “2. / Uruguay / Legal affairs” above).

Contributing Authors

Guyer & Regules

Federico Susena
Montevideo, Uruguay

John Leaman
Montevideo, Uruguay

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Chapter Index:

1. Payment Services / Mobile Payment

2. Asset and Portfolio Management

3. Consulting and Broking Services / Robo-advisory / Auto-trading

4. Trading Platforms / Social Trading Platforms / Signal Following

5. Crowdfunding / Crowdinvesting / Crowdlending

6. Virtual Currency - Bitcoin

7. Loan Services / Factoring / Loan Broking / Finetrading

8. Online Banking Services

9. Analytics and Research / Data Management / Risk Management

10. Accounting

11. Identification

12. Online-pawning

13. InsurTech

14. RegTech

15. Initial Coin Offerings (ICOs)

The information in this guide provides a general overview at the time of publication and is not intended to be a comprehensive review of all legal developments nor should it be taken as opinion or legal advice on the matters covered. It is for general information purposes only and readers should take legal advice from a Multilaw member firm.

Publication Date: 1 August 2019