1. Lifting of the FX Restrictions (“Cepo”) for Individuals

The Communiqué authorizes Argentine-resident individuals to purchase foreign currency without any amount limit for the purpose of holding it (in cash) or depositing it in accounts held at local or foreign financial institutions.

In addition, the Communiqué eliminates the “lock-up periods” during which individuals who had carried the so called “blue-chip swap transactions” (i.e., securities transactions –or similar– aimed at obtaining foreign currency) were barred from accessing the MLC

and vice versa.

2. Exception to the “Lock-Up Period” for Legal Entities

The Communiqué allows legal entities that had engaged in “blue-chip swap transactions” or transferred “local liquid assets” (i.e., peso or peso equivalents) to affiliates before April 11, 2025, to access the MLC, even if the applicable 90-day lock-up period has not yet expired.

According to the Central Bank’s press release issued in connection with the Communiqué, this is a “one-time” measure aimed at “allowing legal entities to resume efficient operations in the MLC.” As such, the restriction remains in place, meaning entities accessing the MLC under this exception will still be subject to the lock-up period for subsequent “blue-chip swap transactions” and vice versa.

3. Dividend Payments

The Communiqué permits the payment of dividends, without any limit on the amount, in respect of distributable profits derived from realized earnings reflected in regular, audited annual financial statements for fiscal years beginning on or after January 1, 2025. This regulation raises questions as it excludes earnings from prior fiscal years and does not address fiscal years starting before that date.

4. Imports of Goods

The Communiqué further relaxes restrictions for the payment of imports by:

• allowing “at sight” payment of all types of goods that have been customs-cleared;

• permitting small and medium-sized enterprises to make advance payments for goods shipped on or after April 14, 2025; and

• allowing advance payment of up to 30% of the price of capital goods, or up to 80% when also considering at-sight and commercial debt payments.

5. Imports of Services

The Communiqué allows payments for services provided by non-affiliates from the date the service is rendered or accrued, eliminating the previously applicable minimum timeframes depending on the nature of the service.

For services provided by affiliates, the payment term has been shortened from 180 to 90 days.

The Communiqué does not address other matters announced by the BCRA in its press release, including the repeal of the “blend” dollar scheme for exporters (which allowed 20% of export proceeds to be settled through “blue-chip swap transactions”), nor the issuance of Bonds for the Reconstruction of a Free Argentina (BOPREAL) to settle outstanding debt that still lacks access to the MLC.