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Survey Category:
Survey Answer:

Yes, the issuance, offering and the carrying out of transactions with e-money (which fells within the definition provided by the law) and electronic wallets is regulated.
E-money is defined by the law as a way of representing cash, for example, by means of prepaid cards, electronic wallets or similar instruments issued by Electronic Money Issuing Institutions or financial intermediation companies.
The law specifically regulates the issuance and circulation of e-money. Moreover, the Compilation of Rules of the Payments System elaborated by the Central Bank of Uruguay provides the essential features of the e-money as follows:
(i) It is stored in electronic media, such as chip, hard drive or servers;
(ii) It is accepted as a means of payment by entities or persons other than the issuer and has a cancellation effect in relation to the obligations contracted with those entities or persons;
(iii) Is issued by a value equal to the funds received by the issuer against its delivery;
(iv) The monetary amount of the electronic money instrument issued is convertible to cash at the request of the holder; and
(v) Does not generate interest.
Digital currencies per-se are not regulated and may or may not fell into the regulation of securities issued by the Uruguayan Central Bank. It should be determined in each specific scenario especially considering the terms of the offering granted to prospective clients to the issuers.

Provided By:
Ferrere Abogados: Martin Pesce, associate / Federico Lemos, associate