Detailed overview
Chile: Fintec Law Cryptoasset Regulation and CMF Supervision
Regulators
Chile’s main regulator for cryptoasset-related financial services is the Comisión para el Mercado Financiero. The Unidad de Análisis Financiero supervises AML, CFT and CPF obligations for reporting entities. The Banco Central de Chile is relevant for payment instruments, payment orders and foreign-currency or fiat-backed digital representations.
Legal framework
Chile regulates many cryptoasset business models under Law No. 21,521, known as the Fintec Law, and CMF Norma de Carácter General No. 502, as amended by Norma de Carácter General No. 524.
Chile is not structured as a single generic VASP licence regime. The result depends on the asset and the activity. A cryptoasset business is regulated where it professionally provides a regulated technology-based financial service in relation to a cryptoasset or other financial instrument.
Regulated services include crowdfunding platforms, alternative transaction systems, credit advice, investment advice, custody of financial instruments, order routing and intermediation of financial instruments.
Cryptoassets and financial instruments
The Fintec Law defines virtual financial assets or cryptoassets as digital representations of units of value, goods or services, excluding money in national or foreign currency, that can be transferred, stored or exchanged digitally.
The law defines financial instruments broadly. A financial instrument includes an intangible asset designed, used or structured to generate monetary returns, represent unpaid debt or represent a virtual financial asset.
For Fintec Law purposes, public-offer securities, money and foreign currency are not financial instruments, even where their support is physical or digital.
Regulated crypto business models
A crypto trading venue may be regulated as an alternative transaction system where it provides a physical or virtual place that allows participants to quote, offer or trade financial instruments or public-offer securities and is not authorized as a stock exchange or product exchange.
A crypto broker or OTC desk may be regulated as intermediation where it buys or sells financial instruments for customers, including where it acts for its own account with the prior intention of selling to or buying from the customer.
A hosted wallet, private-key control service or custodial exchange may be regulated as custody where it holds financial instruments, related money or foreign currency for third parties.
A crypto investment recommendation service may be regulated as investment advice where it provides evaluations or recommendations to third parties about investments or transactions in public-offer securities, financial instruments or investment projects.
A token fundraising platform may be regulated as a crowdfunding platform or under securities rules depending on the legal rights attached to the token and how the offer is structured.
Registration and authorization
Professional providers of regulated Fintec services must be registered in the Registro de Prestadores de Servicios Financieros maintained by the CMF.
Registration alone does not authorize the provider to provide regulated services. Before providing any regulated service, the provider must obtain the specific CMF authorization for that service unless an express exception applies.
An authorization request may be filed with the registration request or after registration. The request must identify the service or services for which authorization is sought. The CMF has a six-month review period, which is suspended while the applicant corrects deficiencies.
New providers should treat Chile as a registration and authorization jurisdiction. A cryptoasset business should not launch a regulated service in Chile merely because it has filed a request.
Current transition position
The main transition period under the Fintec Law and NCG No. 502 has ended.
Existing providers of most regulated Fintec services had to file registration and authorization requests before 3 February 2025. Providers that did not file on time, or whose filings were abandoned or rejected, must stop new regulated operations and may only perform acts needed to conclude existing regulated operations.
A provider that filed a timely authorization request and whose request remains under evaluation may continue operating while the request is under review.
Foreign providers
International companies providing regulated Fintec services generally must have domicile in Chile.
NCG No. 502 contains a narrow exception for foreign providers. A foreign entity can be excepted from the Chilean domicile requirement and from service authorization only where it provides in Chile solely investment advice, credit advice, alternative transaction system services or crowdfunding platform services, and only to qualified investors.
The provider must make the required electronic declaration and update it annually.
The exception does not cover custody, intermediation or order routing. A foreign crypto custodian, broker, hosted wallet or order router should not rely on the qualified-investor foreign-provider exception.
CMF-supervised institutions
Certain institutions already supervised by the CMF can provide specified Fintec services without RPSF registration when acting within their existing legal and regulatory framework. Depending on the service, this may include banks, securities intermediaries, fund managers, insurance companies, product brokers and other institutions authorized by CMF rules.
This is not a general crypto exemption. It depends on the institution, the service and the legal authority under which the institution operates.
Capital and guarantees
Intermediation, order routing and custody can trigger guarantee requirements when the provider reaches the business volume or client thresholds set by the CMF.
Intermediation and custody can also trigger minimum capital requirements. At the statutory level, the required amount is the greater of 5,000 UF or 3% of risk-weighted financial and operational assets. The percentage may be increased up to 6% where there are risk-management deficiencies.
NCG No. 502 applies proportional blocks. Block 1 providers are exempt from minimum capital and guarantee requirements. Block 2 intermediaries and custodians must maintain adjusted capital or guarantees of at least UF 1,000. Block 3 intermediaries and custodians must maintain the greater of UF 5,000 or 3% to 6% of risk-weighted assets. Block 2 and Block 3 order routers must maintain adjusted capital or guarantees of UF 500.
If a provider fails to remedy a capital deficit within the statutory period, it must stop providing intermediation and custody and submit a wind-down and client-transfer program to the CMF.
Custody and private keys
Crypto custody requires specific operational controls.
A custodian must implement policies and procedures covering customer access to instruments and private cryptographic keys, custody records, customer transactions, customer positions, transfers, reconciliations, changes in custody of private cryptographic keys and timely information to customers.
Client accounts and assets must be segregated from the provider’s own assets. Client assets must be clearly identified and may not be reused or lent without customer consent.
A custodial exchange, hosted wallet, MPC provider, private-key control service or omnibus wallet structure should assess whether its custody architecture satisfies these requirements before applying for authorization or onboarding Chilean customers.
Governance, disclosure and reporting
Fintec providers must maintain governance, operational, risk, cyber, disclosure and recordkeeping controls appropriate to their service.
The CMF may require information needed to supervise compliance. Disclosure obligations can include access conditions, system operation, conflicts of interest, interruptions, contingencies, financial and legal condition, recommendation methods and risks, and custody system security and access.
Authorized providers must also comply with CMF periodic reporting through the Fintec Information System Manual. Reporting may include technological infrastructure, cybersecurity, assets custodied, transaction volumes, minimum capital and guarantees, depending on the service and classification.
Providers of regulated services must report annually to the Servicio de Impuestos Internos on customer balances of financial instruments held in custody and transactions carried out through them, in the form and period determined by SII.
Costs
The CMF’s current portal states that RPSF registration costs 17 UF. Service authorization has no CMF filing cost.
This official filing cost is not the total cost of market entry. A provider should separately budget for local setup, governance, legal work, capital, guarantees, compliance, cyber controls, AML controls, custody architecture, reporting systems and audits where applicable.
AML, CFT and CPF
Certain Fintec providers are reporting entities before the Unidad de Análisis Financiero.
The UAF perimeter includes RPSF-registered providers that provide crowdfunding platforms, alternative transaction systems, custody of financial instruments, intermediation of those instruments and payment initiation. CMF-supervised persons that voluntarily register with UAF also become full reporting entities.
UAF Circular No. 62 requires reporting entities to register with the UAF from the beginning of their activity, keep registration data updated and designate a compliance officer.
Reporting entities must maintain AML, CFT and CPF policies and procedures, customer due diligence, beneficial-owner controls, politically exposed person controls, sanctions screening, suspicious-operation reporting, records, a prevention manual and annual staff training.
Suspicious-operation reports have no fixed threshold or periodicity. They must be filed whenever the reporting entity detects a suspicious act, operation or transaction in the course of its activity.
Electronic transfers of funds and assets
UAF Circular No. 62 includes transfer-information obligations for electronic transfers of funds and assets.
For national or cross-border transfers of USD 1,000 or more, including transfers defined in Law No. 21,521, the reporting entity must include precise and significant information on the originator and beneficiary in messages related to the transfer. The information must be verified and retained for at least five years.
Receiving institutions must isolate and manage transfers that do not include required information and decide, based on risk, whether to liquidate, reject, cancel or suspend the transfer.
The transfer-information chapter applies to Law No. 21,521 regulated service providers from 1 July 2025.
Stablecoins and fiat-backed tokens
Fiat-backed or fiat-referenced digital representations require separate payment and Banco Central analysis.
The Fintec Law cryptoasset definition excludes money in national or foreign currency. The financial-instrument definition also excludes money and foreign currency, even if digital.
The Fintec Law amended payment and Banco Central legislation so that certain digital, electronic or informatic representations using distributed ledger or analogous technology can be treated as payment means, payment orders or foreign-currency representations where their value is directly determinable and backed by money, foreign currency or documents payable in those currencies, subject to Banco Central standards.
A peso-backed token, dollar-backed token, redeemable fiat token, payment token or stored-value token should therefore be analyzed under payment and Banco Central rules as well as the Fintec Law.
Securities tokens
Tokenised securities require separate securities-law analysis.
Public-offer securities are excluded from the Fintec Law definition of financial instruments. The Securities Market Law framework requires securities subject to public offering to be registered in the Securities Registry before public offering.
A tokenised share, bond, debt instrument, fund interest, collective investment token, investment contract, asset-backed investment token or other public-offer security should not be treated as an ordinary cryptoasset merely because it is represented digitally.
A platform listing or intermediating those tokens should analyze securities registration, offering rules, market infrastructure, custody, intermediation and CMF authorization requirements.
Regulatory outlook
Chile’s cryptoasset regulation is now operational through the Fintec Law, NCG No. 502, NCG No. 524 and UAF Circular No. 62.
New entrants should treat Chile as a regulated financial-services jurisdiction where crypto activity may require RPSF registration, service-specific CMF authorization, capital and guarantee analysis, custody controls, UAF registration, transfer-information systems, customer disclosures, periodic CMF reporting and tax reporting.
The most important classification points are whether the token is a cryptoasset, public-offer security or fiat-backed payment representation, and whether the provider performs a regulated service such as an alternative transaction system, intermediation, custody, order routing, investment advice or crowdfunding.