Interview | Roberto Silva: "Today, Argentina is sending a clear signal of openness and integration to the world"

Interview | Roberto Silva: "Today, Argentina is sending a clear signal of openness and integration to the world"

In an exclusive conversation with Latin Counsel, we spoke with Roberto E. Silva, president of Argentina’s Securities Commission (CNV), about the process of simplification, deregulation and regulatory modernization currently underway in Argentina’s capital markets.

With more than four decades of experience in the private sector, including as a partner at Marval O’Farrell Mairal, Roberto discusses how his experience advising on complex financing structures, capital markets and financial regulation has shaped a public-sector agenda focused on reducing regulatory friction, modernizing market operations, strengthening investor confidence and expanding access to financing for the real economy.

In this interview, the head of the CNV addresses the recent approval of General Resolution No. 1152, the elimination of Interpretative Criterion No. 99, the balance between regulatory flexibility and risk control, the technological modernization of the market — including digital assets and tokenization — the role of capital markets in relation to the so called "RIGI", and the outlook for activity in the coming years.

Latin Counsel: After more than four decades in private practice, how do you balance the analytical rigor of a top-tier corporate lawyer with the speed required by public-sector management?

Roberto Silva: I started working in a private law firm in 1984. But both in my past in private practice and in my current role in the public sector, I have always tried to work with commitment and speed. Although it may not seem so, on this point there is no difference between the public and private sectors. Both require agility and effectiveness. It is true that in public-sector management we cannot wait, but clients did not wait either. We make every effort to focus on both what is urgent and what is important.

I assumed the position of president of Argentina’s Securities Commission with the conviction that we had to change things, modernize, innovate and make Argentina’s capital markets more flexible in order to promote their development, while also protecting investors. I believe we are achieving that through a great deal of work and by addressing the things that need to be done. I want my time in public office to leave a positive mark. That is why I am here, doing what I am doing.

Latin Counsel: Based on your previous experience in the private sector, what were the main regulatory or administrative obstacles faced by issuers, intermediaries and investors, and how are those experiences being translated into specific reforms at the CNV?

Roberto Silva: Argentina’s capital markets have suffered in the past from the instability of our national currency and the absence of long-term institutional investors, and in recent years they have also operated under a certain degree of regulatory and bureaucratic excess, lack of modernization and unnecessary delays, limiting their potential as a true catalyst for national development.

For that reason, we set out to promote a transformation aligned with the moment we are living through and with the macroeconomic reorganization being carried out by the Argentine Government. We needed a change of mindset, to make procedures easier for issuers, and a reasonable deregulation that supports market development while remaining balanced with investor protection. The corollary of greater freedom is that it brings with it more effective responsibility on the part of those who exercise it.

This is reflected not only in the more than 160 regulations that we have issued, equivalent to almost 15% of all General Resolutions issued since the agency was created in 1968, but, far more importantly, in their content. A simple arithmetic calculation shows that when we took office, the CNV had issued 889 General Resolutions in 58 years of existence, which means an average of 16 General Resolutions per year (a number increased in recent years by the General Resolutions that implemented foreign exchange controls). In 2024 we issued 55 General Resolutions, in 2025 we issued 58, and so far in 2026, as of 29/6/26, we have issued 51. To that must be added 12 Interpretative Criteria. The number speak for themselves.

Among those General Resolutions, broadly speaking, we can mention the easing of foreign exchange restrictions in the capital markets; the regulation of private offerings through the incorporation of a safe harbor; the regulation of Virtual Asset Service Providers (VASPs), expanding the CNV’s regulatory perimeter; the approval of a tokenization regime; the regulatory reorganization of the agency; the creation of the public offering regime with automatic authorization for low- and medium-impact issuances and for frequent issuers; the simplification of procedures for SMEs; and the incorporation of new CEDEARs linked to virtual assets, commodities and indices. We can also mention the regulatory package known as the "Big Bang", which replaces a large part of the prior review processes with automatic authorization frameworks, reducing bureaucracy, accelerating time-to-market, placing the timing of the decision in the hands of CFOs, and aligning local regulation with international standards based on responsibility, transparency and supervision, among many other measures.

Latin Counsel: What management, efficiency and corporate culture practices from the private sector have you successfully incorporated into the CNV’s internal processes?

Roberto Silva: The public sector has a different logic from the private sector, and that requires addressing challenges on several fronts. Since I took office, together with the board of directors that accompanies me, I have set out to work on two levels: first, the normative and regulatory level; and second, the CNV’s internal processes.

On the regulatory front, we have promoted a very deep modernization to accompany the process of stabilization and economic reorganization. The idea was simple: to have clearer rules, less bureaucracy and a more efficient framework that facilitates access to financing and promotes the development of new instruments and investment vehicles. At the same time, we have worked to streamline internal processes and make the CNV more dynamic, efficient and closer to the needs of the market.

Latin Counsel: What change of mindset do you consider most important within the agency and among market participants in order to support a regulatory simplification agenda without losing technical or prudential standards?

Roberto Silva: I believe the most important change of mindset is to understand that simplifying and deregulating does not necessarily mean lowering standards. For a long time, good regulation was associated with a greater number of rules, procedures or prior controls. Our view is different: modern regulation must protect investors and preserve market integrity, but it must do so in the most effective way possible.

That paradigm shift involves both the public and private sectors. It requires adapting to frameworks with less bureaucracy and greater responsibility, where the focus is on transparency, information to the market and risk-based supervision. Like any reform, it is a process of learning and adaptating, but we are convinced that this is the path toward more dynamic and competitive capital markets aligned with international best practices.

Latin Counsel: From the perspective of those who advise international investors, what message would you give today regarding the evolution of legal certainty, regulatory predictability and Argentina’s financial repositioning?

Roberto Silva: Today, Argentina is sending a clear signal of openness and integration to the world. One of the Government’s central objectives is international reintegration, and at the CNV we are working to support that process with simpler rules, less bureaucracy and an increasingly predictable regulatory framework.

At the international level, moreover, we have once again integrated Argentina into the international agenda, both from a regulatory standpoint and through participation in international organizations such as IOSCO (International Organization of Securities Commissions), OECD (Organisation for Economic Co-operation and Development), IIMV (Ibero-American Institute of Securities Markets), FATF (Financial Action Task Force), among others, recovering strategic spaces that our country had occupied in the past and that we had lost. At this time, we continue to work jointly with other State agencies to advance Argentina’s accession process to the OECD.

This year, I was also re-elected as Representative of the Inter-American Regional Committee (IARC) to the International Organization of Securities Commissions (IOSCO) for the 2026-2028 period, following a vote by the member states, and that is a source of great pride for me.

Investment, especially long-term investment, needs predictability. That is why we seek to ensure that rules are clear and stable, and that they facilitate the entry of new investors and the development of new business. The challenge is to continue consolidating that confidence, but we are convinced that we are moving in the right direction to reposition Argentina as an attractive destination for investment and financing.

Latin Counsel: The CNV has been advancing a deregulation, simplification and regulatory flexibility agenda. What is the central diagnosis behind this process, and which regulatory frictions do you consider a priority to remove?

Roberto Silva: The central diagnosis was that there was an excessive number of regulations, requirements and controls that, among other things, ended up generating costs and delays that often bore no adequate proportion to the risks they sought to mitigate. In other words, the principle of proportionality had become unbalanced.

For that reason, we have promoted an agenda aimed at simplifying processes, eliminating unnecessary bureaucracy and reducing market access times. Our objective is for the decision as to when to issue or access the market to be increasingly in the hands of companies and their CFOs, and not conditioned by regulatory procedures that add little value.

Along those lines, we advanced with the public offering regime with automatic authorization, the simplification of issuance programs and the regulatory package known as the "Big Bang", which transformed many prior review procedures into more agile and efficient frameworks. The priority is to remove obstacles that hinder financing and innovation, while at the same time maintaining appropriate standards of transparency, investor information and supervision.

Latin Counsel: The approval of General Resolution No. 1152 and the elimination of Interpretative Criterion No. 99 mark a relevant change for the own portfolios of settlement and clearing agents. What market signals indicated that this was the right time to move forward with that flexibility?

Roberto Silva: Rather than responding to a specific market signal, this flexibility forms part of a gradual process of reviewing restrictions that had been established in a different context. First, we eliminated dollar-denominated market loans as a restriction and, subsequently, through Interpretative Criterion No. 99, we incorporated exceptions that allowed certain intraday transactions.

General Resolution No. 1152 deepens that path, expanding the exceptions for agents’ own portfolios and granting them greater operational flexibility. The objective was to adapt regulation to the real needs of the market, preventing restrictions that had already lost part of their justification from generating inefficiencies or hindering the proper management of intermediaries’ positions.
Ultimately, we seek to facilitate trading without affecting the objectives of supervision and transparency, allowing agents to operate with greater efficiency and fewer regulatory obstacles.

Latin Counsel: What impact do you expect the exception allowing positions in foreign currency to be restored up to 15% of net worth to have on daily liquidity, institutional trading and price formation in the market?

Roberto Silva: It is not about any of those things. What it does is establish clear rules as to the circumstances in which ALyCs (classical stock brokers) and ANs (negotiation agents) may dollarize their own portfolios. The objective of the rule is, fundamentally, to provide greater clarity and predictability regarding the circumstances in which those agents may restore foreign-currency positions within their own portfolios.

Moreover, this flexibility does not operate in isolation. It is accompanied by the prudential requirements and existing limits on liquidity and leverage, which must be met both in pesos and in dollars, and also on a consolidated basis. Therefore, it is a regulatory adjustment that seeks to facilitate portfolio management within a control and supervision framework that remains fully in force.

Latin Counsel: From a risk-control standpoint, how does the CNV offset the elimination of the prior restrictions under Interpretative Criterion No. 99 with the new monthly reporting regime?

Roberto Silva: Interpretative Criterion No. 99 did not establish restrictions; rather, it introduced an exception within the general regime already in force. In that sense, the new framework does not imply an update and expansion of those exceptions within a clearer framework.

This change is complemented by the prudential limits on liquidity and leverage that agents must comply with, both in local and foreign currency and on a consolidated basis. Added to this is the monthly reporting regime, which reinforces supervision by allowing more systematic and timely monitoring of positions.

Taken together, the objective is to maintain a solid risk-control framework, but with clearer, more coherent rules aligned with the market’s actual operations.

Latin Counsel: How does General Resolution No. 1152 fit into the broader objective of normalizing the capital markets and leaving behind exceptional measures linked to the context of foreign exchange controls and restrictions?

Roberto Silva: General Resolution No. 1152 is aligned with the easing of restrictions that we have been promoting since the beginning of this administration with the objective of normalizing Argentina’s capital markets. We have been moving consistently in that direction through different resolutions that have made the regulatory framework more flexible and orderly. These include the elimination of the prohibition on the dollarization of ALyCs’ own portfolios (General Resolution No. 990), the review of restrictions linked to transactions involving BOPREAL -a Central Bank bond- (General Resolutions Nos. 990 and 995), the elimination of obstacles to transactions associated with UVA -inflation adjusted- mortgage loans (General Resolution No. 1004), the elimination of the five-day prior notice requirement (General Resolution No. 1018), and the relaxation of certain dollar-denominated financings that prevented operations in MEP -local USD- or CCL -USD delivered abroad- (General Resolution No. 1018).

Added to this are the elimination of "parking" requirement for resident individuals (General Resolution No. 1062) and the expansion of criteria for the free transfer of securities acquired in primary placements or reinvestment, across different regulatory stages (General Resolutions Nos. 1022, 1067, 1068, 1093 and 1128), among other measures.

Latin Counsel: By relaxing the requirements for updating prospectuses and making certain duties optional, how does the CNV ensure an adequate standard of transparency without imposing unnecessary costs on issuers?

Roberto Silva: The CNV must always balance two things: on the one hand, promoting the development of capital markets and, on the other, protecting investors. This flexibility regarding certain prospectus updating requirements, or the possibility that some duties become optional, is framed within that balance.

What matters is that the central obligation does not change: the obligation to provide adequate, complete and sufficient information so that investors can make informed decisions remains intact (regardless of whether it is contained in the prospectus or the supplement). What is being done is to reduce administrative burden and simplify processes that did not add value, but without affecting the aforementioned disclosure standard.

At the same time, the responsibility of each of the market participants — issuers, placement agents and their advisers — is reinforced, and they remain subject to administrative, civil and criminal liability regimes. Ultimately, this is not less transparency or less control, but less bureaucracy and greater commitment, without State paternalism.

Latin Counsel: One of the historical challenges of the Argentine market has been to broaden the issuer base. Which measures do you consider most relevant for more companies, especially medium-sized companies, to access public financing?

Roberto Silva: Without a doubt, one of the challenges we face is to broaden the issuer base, especially by bringing more small and medium-sized companies into financing through the capital markets.

SME financing is a central pillar, together with tools such as the hard-dollar promissory note (General Resolution No. 1003), which provides access to foreign-currency financing in a more agile way adapted to current needs.
Along these lines, we have been working on SME financing as a key pillar. In this regard, notable developments include the development of SME Mutual Funds (General Resolution No. 997), the expansion of financing through Mutual Funds and SME financial trusts (General Resolution No. 1019), and the extension thereof through General Resolution No. 1070.

This is complemented by the extension of the automatic public offering regime for low- and medium-impact issuances, including financial trusts and other vehicles (General Resolution No. 1031), as well as the incorporation of negotiable obligations into this framework (General Resolutions Nos. 1047 and 1028).

We have also advanced in flexibility and regulatory reorganization regarding the issuance and trading of Individually Issued Negotiable Securities (VNEI), through General Resolution No. 1107.

In addition, we approved greater simplification of the regime through new expansions for low- and medium-impact financial trusts and the opening of the automatic public offering regime to retail investors for issuers under the general regime, both in negotiable obligations and shares (General Resolution No. 1117).

This entire process is strengthened by the "Big Bang" deregulatory package (General Resolutions Nos. 1145 to 1149), which consolidates a logic of greater simplification, less bureaucracy and more automation, with the objective of enabling more companies — especially medium-sized companies — to access public financing more quickly, efficiently and predictably.

Latin Counsel: In corporate finance, which instruments do you expect to gain greater momentum in the coming years: negotiable obligations, financial trusts, shares, closed-end mutual funds, investment funds or other vehicles?

Roberto Silva: Since we began our administration, market volume has doubled. This is not a coincidence; it has been driven by the macroeconomic stability promoted by the Argentine Government and by the regulatory framework we have issued so that accessing the market is easier and more efficient.

Some instruments have already shown very significant development, such as negotiable obligations (ONs), while others have even greater expansion potential going forward.

In that regard, ONs will certainly deepen their growth, especially with the impact of the "Big Bang" regulatory package, which improves access, reduces timing and facilitates issuances. Something similar can be expected of open-end mutual funds, which under this new framework — and with the addition of the development of FALs — should multiply their scale and the number of available vehicles.

We also see very significant room for closed-end funds, especially those linked to financing the real economy and, in particular, the development of the real estate market, which may gain significant momentum in a context of greater macroeconomic stability and greater regulatory dynamism.

In the case of financial trusts, although they have not experienced the growth expected in recent years, we have made significant progress in simplifying their rules in order to facilitate their development.

Finally, instruments such as marketable promissory notes, deferred-payment checks and electronic credit invoices should sustain their volume and even expand, particularly as a result of their greater trading on platforms.

Latin Counsel: The technological modernization of the market appears as one of the pillars of the regulatory agenda. What regulatory, operational and technical infrastructure plans does the CNV have on its agenda to digitalize Argentina’s securities market and make it more efficient?

Roberto Silva: Markets are incorporating technology on an ongoing basis, and at the CNV we have been actively supporting that process by promoting a regulatory framework that enables and organizes those innovations rather than restricting them.

In that regard, the regulation of VASPs and the development of the tokenization framework mark a turning point, as they formally integrate new technologies into the capital markets and provide them with a clear regulatory framework.

Rather than thinking in terms of a single closed plan, what exists is a continuous modernization agenda that seeks to ensure that regulation accompanies technological evolution, facilitating greater operational efficiency, traceability and market access, always within standards of transparency and investor protection.

In addition, through General Resolution No. 1000, the regulation was amended to set the regular settlement period at T+1 for transactions involving equity and/or fixed-income negotiable securities. The regular settlement period of T+2 was maintained only for certain transactions and for a short period, until General Resolution No. 1029 completely eliminated it. By aligning ourselves with the highest global standard settlement periods and providing investors with a more agile liquidity window, when they sell, they receive the proceeds of the transaction sooner; when they buy, they can contribute the funds one day later. In short, we are aiming for a market that can organically flow with greater speed and be integrated with the world.

Latin Counsel: In relation to digital assets and tokenization, what is the legal roadmap for allowing the listing or regulated trading of instruments linked to these assets in traditional markets?

Roberto Silva: Today we are still facing two worlds that operate relatively separately — the traditional market and the virtual asset ecosystem — but with a clear trend toward convergence.

Tokenization, as we conceive it, involves precisely that interaction between both spaces: bringing real-world assets into digital representations without losing the anchor in the legal regime of the capital markets.

In that regard, the regulatory roadmap is aimed at enabling that integration in a gradual and orderly manner, ensuring that any listing or trading of instruments linked to digital assets in traditional markets takes place within frameworks that guarantee transparency, traceability, investor protection and adequate supervision. The challenge is to build bridges between both systems without giving up regulatory standards.

Latin Counsel: How does the CNV regulate Virtual Asset Service Providers, markets, and coordinate with other regulators to comply with international standards on fraud prevention, anti-money laundering and investor protection?

Roberto Silva: Today we can state with satisfaction that Argentina is at the forefront in the region — and even compared with many countries around the world — in the regulation of Virtual Asset Service Providers (VASPs) and tokenization.

In just over two years of sustained work since the enactment of Law No. 27,739, which entrusted to the CNV the registration and supervision of VASPs within the framework of the system for the prevention of money laundering and terrorist financing, we have succeeded in building a comprehensive regulatory framework aligned with international standards and FATF recommendations.

We assumed a central role in the design and implementation of this framework, with the objective of providing predictability, security and transparency to the development of the activity. In that process, we first advanced with the creation of the VASP Registry through General Resolution No. 994, during the FATF mutual evaluation; then we opened a public consultation process through General Resolution No. 1025, incorporating input from the sector; and finally, we consolidated the definitive regulation through General Resolution No. 1058, which is now fully in force.

This development did not take place in isolation, but in permanent coordination with other State agencies, particularly the UIF in relation to anti-money laundering, reinforcing an integrated approach to supervision and control.

Ultimately, the objective is clear: to accompany financial innovation, but within a robust framework that guarantees integrity, traceability and investor protection, in line with the highest international standards.

Latin Counsel: Looking ahead to the next two years, which indicators would make it possible to measure the success of this agenda: greater transactional volume, entry of new issuers, greater depth and liquidity, participation by retail investors, foreign investment or new substantive legal reforms?

Roberto Silva: Everything we have done already constitutes an indicator of success in itself, to the extent that the market’s own growth and the reception of the reforms show a concrete change in how it operates.

That change is reflected in more agile access to the market, in improved timing for financing decisions and in greater operational ease for issuers and investors. In that sense, rather than thinking about isolated indicators going forward, what we already see is an effective transformation in the dynamics of the market as a result of the reforms implemented. We are changing the history of Argentina’s capital markets, and that is something that can be seen in practice today.

Argentina deserves a capital market commensurate with the new stage it is undergoing.