All e-Wallets Must Be CBU/CVU or Alias-Compatible to Enable Payments by Transfers

On September 10, 2021, the Argentine Central Bank (the “BCRA,” after its acronym in Spanish) issued Communique “A” 7363 (the “Communique”) ordering financial entities and payment service providers that offer payment accounts (“PSPOCP,” after its acronym in Spanish), known as “digital wallets” or similar names, to meet the following requirements:

• To allow wallet holders to connect their own or joint bank and payment accounts using their account code (known as CBU/CVU or ALIAS, after their acronyms in Spanish).

• To set up the necessary mechanisms for wallet holders to make transfers from those accounts.

• To notify their clients of these measures through the usual communication channels.

These provisions must be implemented and operational by December 1, 2021.

Because the phrasing of the first point in the Communique could be interpreted as creating a new system of absolute openness and interoperability under the same user interface as the “open banking” models found in other countries around the world, the BCRA unofficially ruled out that interpretation.

Thus, the purpose of the Communique is to ensure that e-wallets do not require an associated debit card to operate and make payments and are instead necessarily associated to a CBU/CVU or Alias for direct transfers without using the cards system pursuant to the Transfers 3.0 Program, which will be fully operational starting November 29th of this year. Although, in practice, PSPOCP wallets already had this feature to meet market demands, certain financial institution wallets only allowed payments by debit card associated to the client's bank account.