Introduction

Attitude of the country towards modern financial advisory and broking services

• Financial advisory and brokerage are public-interest activities, strictly regulated by Ley N° 393.
• Only ASFI-licensed entities can legally offer these services.
• Unregulated or informal advisory—even digital or cross-border—is generally not allowed.
• The government focuses on consumer protection, avoiding speculation, and tightly controlling intermediaries.

• Robo-advisors and automated financial advice platforms are not directly regulated or recognized.
• Such services must fit under existing categories like financial auxiliaries or brokerages.
• There is no regulatory sandbox to test new digital models.
• Implication: FinTechs must work within outdated frameworks not made for digital advisory.

• Most retail consumers rely on bank staff, not independent advisors.
• Financial literacy and knowledge of investments or retirement planning are low.
• Preference is for fixed income, bank products, or physical assets like real estate and gold.
• Opportunity: FinTechs can grow demand by integrating financial education.

• The Bolsa Boliviana de Valores (BBV) oversees a few licensed brokerage firms.
• Brokers face capital, compliance, and disclosure rules.
• Retail trading is very limited; mostly institutional or wealthy clients trade securities.
• Online discount brokerage models (e.g., Robinhood) do not operate here.

• Bolivia prioritizes financial stability, inclusion, and national control over rapid innovation or foreign platforms.
• Regulators are cautious about fast-growing or risky FinTechs, especially in retail speculation or crypto products.
• FinTechs should emphasize:
• Inclusion and education
• Strong compliance and local partnerships
• Transparent, low-risk offerings

Legal affairs

Obligations and requirements to provide financial advisory and broking services, or ancillary services described above

• Financial advisory, broking, asset management, investment analysis, and portfolio structuring are regulated activities in Bolivia.
• Companies and individuals must comply with these laws and regulations:
• Ley del Mercado de Valores (Law No. 1834, 1998)
• Ley de Servicios Financieros (Law No. 393, 2013)
• Specific rules from the Autoridad de Supervisión del Sistema Financiero (ASFI)
• Regulations from the Bolsa Boliviana de Valores (BBV)
• Since 2025, Decreto Supremo No. 5384 for FinTech-related investment services.

• Decree Supremo N° 5384 recognizes new FinTech services like robo-advisors, automated portfolio platforms, tokenized investments, and digital advisory tools.
• These can operate in a regulatory sandbox: FinTechs can apply for temporary licenses, launch under supervision, and test products.
• Note: ASFI has not yet published full regulations, so implementation is still pending.

• Providing financial advice or brokerage without proper license is a criminal offense.
• Foreign platforms without a local license cannot legally serve Bolivian users.
• Crypto-based portfolios or asset management without authorization remain restricted or in a legal gray area.

• Create a legal entity in Bolivia with the right corporate purpose.
• Get authorization from ASFI or BBV.
• Employ certified professionals and meet qualification standards.
• Implement AML, compliance, and risk management systems.
• Fully disclose fees, risks, and conflicts to clients.
• Submit regular reports and remain supervised.
• For FinTechs: apply to the sandbox under Decreto 5384 (when regulations are available) and consider partnering with a licensed local firm.

Additional comments regarding the legal situation for financial advisory and broking services, or adjacent services or what FinTech’s must be aware of in this business area

• Bolivia’s laws focus on traditional, in-person advisory models.
• Decree 5384 (2025) opens the door for digital advisory via sandbox but full legal clarity is still missing.
• Without explicit authorization, digital advisory FinTechs risk being illegal.

• Tokenized assets and crypto are not fully regulated yet.
• Services involving crypto investment advice or token portfolios are still mostly prohibited or in a gray zone.
• FinTechs should avoid public crypto offerings until ASFI clarifies rules.

• Foreign firms serving Bolivians without local registration break the law.
• ASFI and BBV have warned against unlicensed Forex, investment advice, and high-risk products online.
• FinTechs should form a local company, partner with licensed entities, or enter the sandbox.

• Full AML/CFT rules apply equally to digital and traditional advisors.
• FinTechs need KYC, transaction monitoring, automated reporting, and compliance officers.
• No simplified regimes exist; even startups face strict rules.

• Advisors must assess client risk profiles and ensure suitable recommendations.
• Fees, risks, and commissions must be clearly disclosed.
• Robo-advisors must have auditable logic to meet these standards, despite unclear regulation.

• ASFI is still drafting secondary regulations covering licensing, capital requirements, risk models, and cross-border partnerships.
• Uncertainty remains about exact rules for digital advisory and asset management.

Economic conditions

Market size for financial advisory and broking services as well as adjacent services and biggest companies in this business area

• The sector is small but growing due to:
• Low retail investor participation (low financial literacy and limited banking access).
• Dependence on high-net-worth individuals (HNWIs) and institutional clients.
• Increasing demand for corporate advisory (capital markets, debt issuance).
• Estimated market value: US$50–70 million annually in advisory fees and commissions (retail + institutional).
• FinTech advisory: Still nascent, but expected to grow 20–30% annually in the next 3–5 years with regulatory reforms (e.g., Decreto 5384).

• The Bolsa Boliviana de Valores (BBV) is small and less liquid compared to regional peers.
• Annual trading volume: ~US$300–500 million in equities and fixed income.
• Brokerage revenues: US$15–25 million annually (commissions, underwriting, ancillary services).

• Includes fund administration, custody, investment research, robo-advisory pilots, and financial consulting.
• Still small but high growth potential due to fintech adoption and increasing investor interest.

• Banco Mercantil Santa Cruz (BMSC): Leading corporate finance, wealth management, and brokerage (via Mercantil Valores).
• Banco Nacional de Bolivia (BNB): Strong retail and corporate advisory services.
• Banco Económico (ECO): Active in brokerage with digital expansion.
• Banco BISA: Advisory and asset management for institutional and private clients.

• Mercantil Valores: Largest by trading volume, offering full brokerage and underwriting.
• BISA Valores: Focus on institutional brokerage and fixed income.
• Bolsa Boliviana de Valores: Retail-oriented brokerage.
• BBV: Stock exchange that also provides training and partnerships.

• Early-stage startups offering robo-advisory and digital portfolios under Decreto 5384.
• Tokenized or blockchain-based investment pilots, often in collaboration with banks or foreign partners.

Additional comments regarding the economic situation for financial advisory and broking services as well as adjacent services or what FinTech’s must be aware of in this business area

• Bolivia’s economy is growing moderately but remains vulnerable to:
• Commodity price swings (gas, minerals).
• Currency controls and volatility.
• Inflation reducing disposable income and investment interest.
• Low per capita income and limited financial inclusion restrict retail demand for advisory and brokerage.
• The large informal economy means many potential clients are outside the formal financial system.

• The sector is dominated by a few major banks and licensed brokerages.
• High barriers: licensing costs, strict compliance, and the need to build trust.
• FinTech entrants often need to partner with incumbents or focus on niche segments (e.g., digital wealth tools for younger urban users).

• Mobile and internet use is growing (~70% smartphone penetration in urban areas).
• Younger generations and SMEs want affordable, transparent, digital investment advice.
• Decree 5384 supports FinTech innovation, but its full implementation is still in progress.

• Full AML/CFT, data protection, and client suitability rules apply.
• No simplified regime for digital-only players yet.
• Crypto and tokenized asset regulations are unclear, limiting product innovation.
• Regulatory sandboxes offer opportunities but require early coordination with ASFI.

• Low financial literacy means FinTechs must invest in education, transparency, and user-friendly tools.
• Localized content and clear risk/fee disclosures are essential to build trust.