The virtual assets ecosystem has grown exponentially in Bolivia in recent years. This expansion, driven by technology and innovation, has also created regulatory challenges for authorities responsible for preventing financial crimes. In this context, the Financial Investigations Unit (UIF) has resumed and strengthened its supervisory role over these services through the issuance of Administrative Resolution No. 19/2025, published on April 19, 2025.

Evolving Framework: Regulatory Background

RA-19/25 does not emerge in isolation. It is part of a series of efforts that began in December 2024, when the UIF issued Administrative Resolution No. 58/2024, which, for the first time, designated Virtual Asset Service Providers (VASPs) as Obligated Subjects. However, in response to various inquiries from the sector and with the aim of clarifying the scope of this designation, the UIF temporarily suspended its application through RA-60/2024.

That pause allowed for feedback collection, review of definitions, and adjustment of the regulatory approach. As a result of this review process, RA-19/25 reinstates the regulation, establishes obligations with greater precision, and clarifies the entities covered.

Who Are Considered VASPs under RA-19/25?

According to this new resolution, all natural or legal persons who perform any of the following activities, for or on behalf of a third party, must register as Obligated Subjects with the UIF:

• Exchange between virtual assets and fiat currencies;
• Exchange between different types of virtual assets;
• Transfer of virtual assets;
• Custody or administration of virtual assets or instruments that allow control over them;
• Participation in or provision of financial services related to the offer or sale of virtual assets.

Key Obligations for VASPs

Once registered with the UIF, these providers must comply with a series of responsibilities under anti-money laundering regulations, including:

• Implementation of due diligence and Know Your Customer (KYC) policies;
• Appointment of a Responsible Officer (RO) to liaise with the UIF;
• Monitoring and reporting of suspicious transactions;
• Record-keeping for at least 10 years;
• Periodic updates of customer and ultimate beneficiary information.

Why Is Compliance with This Regulation Important?

The inclusion of VASPs as Obligated Subjects represents a regulatory milestone aimed at providing the Bolivian financial system with control mechanisms for an emerging yet potentially misuse-prone activity.

Beyond being a formal requirement, compliance with this regulation means adopting a culture of accountability that builds trust in the market. Non-compliance may lead to administrative sanctions, operational restrictions, and even criminal consequences.

Could Your Activity Be Affected by This Regulation?

If your company, startup, or digital platform offers services related to the management of virtual assets (exchange, wallets, custody, tokenization, etc.), it is essential to assess whether you fall under RA-19/25 and how to adapt your compliance structure.

At Dentons Guevara & Gutierrez, we provide specialized advisory services for operators in the digital ecosystem, helping them meet new obligations and position themselves securely and responsibly in the market.