Yesterday, the BCRA issued Communications “A” 8360 (https://lnkd.in/dTEt_T2g) and 8361 (https://lnkd.in/dBiEetmk), through which it has amended the Consolidated Text on Foreign Exchange Regulations applicable to transactions carried out both by individuals and banking institutions.
The provisions set forth in Communication “A” 8360 have a direct impact on banking entities, as they amend the regulations governing the Net Global Foreign Currency Position (Posición Global Neta de Moneda Extranjera – PGNME), which establishes the exposure limits that institutions may hold in U.S. dollars and other foreign currencies. As from today, December 10, 2025, banks that purchase U.S. dollar–denominated Treasury securities through primary subscription must immobilize such securities for a period of 90 days, during which they may not be sold on the secondary market without affecting the institution’s foreign currency position.
Furthermore, the period granted to banking entities to adjust certain transactions related to the PGNME—such as, for example, offsetting purchases and sales of foreign-currency-denominated assets in order to comply with the regulated limit—is reduced from 300 calendar days to 90 calendar days.
On another note, Communication “A” 8361 introduces certain exceptions to the restriction imposed by Communication “A” 8336, which established that individuals accessing the official foreign exchange market for the purchase of foreign currency must execute an affidavit undertaking not to engage, whether directly or indirectly or on behalf of or for the account of third parties, in purchases of securities settled in foreign currency from the moment access is requested and for a period of 90 consecutive days thereafter. The transactions excluded from this affidavit requirement are: (i) primary subscriptions of debt securities issued by residents, provided that the purchaser holds such securities in its portfolio for at least 15 business days; and (ii) the reinvestment of interest payments and principal amortizations of securities issued by the National Treasury or the BCRA in U.S. dollars within 15 business days following the collection thereof.