Argentina

Last updated: 1 July 2026

Operational Transition Notice: these Argentina Terms have been amended as of 1 July 2026 to reflect the definitive suspension of the ordinary commercial vertical for virtual assets in the region and the entry into force of the Transition and Balance Liquidation Plan mandatorily governed by Annex B of this document.

1. Acceptance and Scope

These Terms and Conditions (the "Argentina Terms") govern access to and use of the BNKA.com technology platform (the "Platform") by natural persons resident in the Argentine Republic. Access to, registration on, or use of the Platform means the user declares to have read, understood, and fully accepted these Argentina Terms. If the user does not agree with them, they must refrain from using the Platform.

These Argentina Terms supplement the BNKA General Terms and Conditions. In the event of any conflict or contradiction, these Argentina Terms shall prevail with respect to services and users located in the Argentine Republic.

2. Definitions

For the purposes of these Argentina Terms, the following shall apply:

• "Platform": the technology interface accessible through BNKA.com and/or associated applications.
• "User": a natural person resident in the Argentine Republic who accesses and uses the Platform.
• "PSP": a Payment Service Provider under the regulations of the Central Bank of the Argentine Republic (BCRA).
• "PSAV": a Virtual Asset Service Provider under the regulations of the National Securities Commission (CNV).
• "CVU": the Uniform Virtual Key associated with a payment account.
• "PSP Services": payment account services (CVU), transfers, and payments in Argentine pesos.
• "PSAV Services": services related to virtual assets historically provided by the registered PSAV. As of 1 July 2026, these services are discontinued for ordinary commercial operations (purchases, deposits, inflows) and are strictly limited to the exceptional evacuation, withdrawal, exit-sale, and technical wind-down functionalities detailed in Annex B.

3. Nature of BNKA.com and Neoxpat Limited

The Platform is technologically operated by Neoxpat Limited, which acts solely as a technology infrastructure and digital interface provider. For regulatory purposes in the Argentine Republic, it is expressly stated that BNKA.com and Neoxpat Limited:

• are not a bank;
• are not a Payment Service Provider (PSP);
• are not a Virtual Asset Service Provider (PSAV);
• do not provide regulated financial services;
• do not hold custody of user funds;
• do not process payments;
• do not issue electronic money;
• do not grant credit;
• do not execute crypto-asset transactions.

The Platform does not execute financial transactions; rather, it allows the user to access and initiate instructions with respect to services provided by duly authorized, independent third parties.

4. Service-Providing Entities in Argentina (Strict Segregation of Roles)

In the Argentine Republic, the services accessible through the Platform are provided by independent entities, each within the scope of its respective authorization and under its own exclusive responsibility.

4.1 Block Digital Services S.A. – Payment Service Provider (PSP)

Block Digital Services S.A. is a company incorporated under the laws of the Argentine Republic, registered as a Payment Service Provider with the BCRA.

Block Digital Services S.A. is the sole entity responsible for providing the PSP Services, including:

• opening and administering CVU payment accounts;
• inflow, outflow, and administration of funds in Argentine pesos;
• local transfers;
• payments and other payment services permitted under BCRA regulations.

Block Digital Services S.A. provides exclusively fiat currency (Argentine peso) services and does not provide virtual asset services, does not act as a PSAV, and does not buy, sell, broker, or hold custody of crypto-assets.

4.2 Digital Trading S.A. – Virtual Asset Service Provider (PSAV)

Digital Trading S.A. is a company incorporated under the laws of the Argentine Republic, registered as a Virtual Asset Service Provider with the CNV. Effective as of 1 July 2026, Digital Trading S.A. permanently discontinues the commercial offering, deposit-taking, or inflow of new virtual assets.

Its responsibility and functions are limited exclusively to acting as the operational support for the transitional liquidation window, allowing, on a restricted basis, exit exchange (swap to pesos), on-chain withdrawal of remaining historical balances to external wallets, and the subsequent segregated custody of orphaned balances subject to a penalty, all under the conditions of Annex B.

The PSAV Services are not provided by Block Digital Services S.A., nor by BNKA.com, nor by Neoxpat Limited.

5. Segregation of Services, Funds, and Liabilities

The PSP Services and the PSAV Services are strictly segregated in terms of:

• contract;
• operations;
• regulation;
• liability.

In particular:

• Funds credited to CVU accounts: do not constitute bank deposits; are not covered by the deposit guarantee scheme; are used exclusively for PSP Services; are not allocated or linked to crypto-asset transactions.
• Any virtual asset transaction: is executed solely by Digital Trading S.A.; under its own regulatory framework; and under its own exclusive liability to the user.
• Treatment of Exceptional Balances: any virtual asset balance greater than zero (>0) not autonomously withdrawn by the User before the Deadline set out in Annex B will require processing through a manual withdrawal channel managed via support, will cease to be displayed or automatically operable within the ordinary mobile app environment, and will accrue the Administrative Fee for Custody of Inactive Balances provided for therein, in favor of the PSAV, to cover infrastructure costs and extraordinary key maintenance.

6. Platform Functionalities

The Platform functions solely as a technology infrastructure interface. With respect to fiat currency (Argentine pesos), it retains its ordinary functions for viewing and instructing transfers and payment accounts (CVU). With respect to the virtual asset vertical, ordinary functionalities are disabled, with the mobile app interface operating in an exclusive "Withdrawal-Only" environment for the wind-down of balances in accordance with the technical terms and deadlines of Annex B.

7. Contractual Relationship

The user acknowledges and accepts that:

• with respect to the PSP Services, they enter into a direct and independent contract with Block Digital Services S.A.;
• with respect to the PSAV Services, they enter into a direct and independent contract with Digital Trading S.A.;
• BNKA.com and Neoxpat Limited are not parties to the regulated financial services contracts.

Each entity is liable solely for the services it provides.

8. Registration, KYC, AML/CFT, and Compliance Powers

Access to the services is subject to compliance with the following processes:

• identification and identity verification (KYC);
• anti-money laundering and counter-terrorist financing (AML/CFT) measures;
• other applicable regulatory controls.

The service-providing entities may, in accordance with applicable regulations:

• request additional information;
• apply operational limits;
• delay, reject, or block transactions;
• suspend or cancel services.

9. Security, Errors, and Unauthorized Transactions

The user is responsible for the confidentiality of their credentials and devices.

Any unauthorized transaction, error, or complaint must be reported immediately through official channels.

Complaints will be handled by the entity responsible for the corresponding service.

10. Fees, Costs, and Taxes

Applicable fees and charges will be disclosed by the service-providing entity before the execution of each transaction. Any applicable taxes and/or withholdings will be applied in accordance with current regulations. The user is responsible for their own personal tax obligations.

11. Limitation of Liability

BNKA.com and Neoxpat Limited shall not be liable for:

• acts or omissions of Block Digital Services S.A. or Digital Trading S.A.;
• losses arising from PSP or PSAV Services;
• fluctuations in the value of virtual assets;
• interruptions attributable to third parties or causes beyond their reasonable control.

Nothing herein limits any non-waivable consumer rights under Argentine law.

12. Suspension and Termination

BNKA.com may suspend or restrict access to the Platform in response to:

• legal or regulatory requirements;
• security incidents;
• indications of fraud;
• operational or compliance risks.

The service-providing entities may immediately suspend the relationship upon well-founded suspicion of fraud or regulatory breaches, or terminate the ordinary contractual relationship by notifying the user with the legally required advance notice, in accordance with their own terms and applicable regulations.

13. Governing Law and Jurisdiction

These Argentina Terms are governed by the laws of the Argentine Republic.

Any dispute shall be submitted to the jurisdiction of the competent courts of the Argentine Republic, without prejudice to consumer rights.