Argentina

O'Farrell advised John Deere Credit Compañía Financiera S.A. and EGFA Abogados advised Banco de Galicia y Buenos Aires S.A., Banco Santander Argentina S.A., and Balanz Capital Valores S.A.U., as organizers and placement agents in the offering and issuance of Additional Class XVIII Notes denominated and payable in US in Argentina dollars at a fixed annual nominal rate of 8,5% and maturing in 2027 for a total amount of US$ 27,691,000. The Additional Class XVIII Notes were issued on September 5, 2025, under the Frequent Issuer Regime established in Section VIII, Chapter V, Title II of the CNV Regulations. The Additional Class XVIII Notes have been authorized for listing on Bolsas y Mercados Buenos Aires S.A. (BYMA) through the Bolsa de Comercio de Buenos Aires S.A. (BCBA) and for trading on the A3 Mercados S.A. (A3). Legal advice to John Deere Credit Compañía Financiera S.A. O'Farrell: Partner Sebastián Luegmayer, Senior Consultant Nicolás Fernández Madero and associate Irupé Martínez. Legal advice to the Placement Agents EGFA Abogados: Partner Carolina Curzi and associates María Constanza Martella, Agustina Weil and Marina Galíndez.

O’Farrell advised Scania Credit Argentina S.A.U. on its first issuance of notes in the Argentine capital markets, marking a historic milestone in its financial and institutional development. The issuance of Class 1 Notes, denominated and payable in U.S. dollars, took place on September 5, 2025, for a total amount of US$ 28,719,227, at a fixed annual nominal rate of 8.75% and maturing in September 2027. The result reflects investors’ confidence in the company’s financial strength and its long-term growth plan. The Class 1 Notes were issued under the company’s Global Notes Program approved by the Argentine Securities Commission (Comisión Nacional de Valores), pursuant to Section IV, Chapter V, Title II of its Rules. The Notes were authorized for listing on Bolsas y Mercados Argentinos S.A. (BYMA) through the Buenos Aires Stock Exchange (BCBA), and for trading on A3 Mercados S.A. (A3). PAGBAM advised Banco Santander Argentina S.A. as organizer and placement agent, and Banco Santander Argentina S.A., Industrial and Commercial Bank of China (Argentina) S.A.U., Balanz Capital Valores S.A.U., Banco BBVA Argentina S.A., Puente Hnos. S.A., PP Inversiones S.A., Global Valores S.A., Allaria S.A. and Adcap Securities Argentina S.A., as placement agents. Legal advice to Scania Credit Argentina S.A.U. O'Farrell: Partner Sebastián Luegmayer, Senior Consultant Nicolás Fernández Madero and associate Irupé Martínez. Internal Legal Advisors: Martín Garat and Verónica Monsalve. Legal advice to the Organizer and the Placement Agents Perez Alati, Grondona, Benites & Arntsen: Partner Diego Serrano Redonnet, Counselor Nicolás Aberastury and associates Juan Ignacio Rodriguez Goñi, Tamara Friedenberger, Catalina Hermida Pini and Juan Hernán Bertoni.

O'Farrell advised John Deere Credit Compañia Financiera S.A. and EGFA Abogados advised Banco de Galicia y Buenos Aires S.A.U., Banco Santander Argentina S.A., Banco BBVA Argentina S.A., Balanz Capital Valores S.A.U., Banco Patagonia S.A., Macro Securities S.A.U., Puente Hnos S.A. and Banco Comafi S.A., as organizers and placement agents in the offering and issuance of Series XVII Notes denominated and payable in US dollars at a fixed annual nominal rate of 7,5% and maturing in 2027 for a total amount of US$ 42,131,380. The issuance of the Series XVII Notes was carried out on May 27, 2025, under the Frequent Issuer Regime established in Section VIII, Chapter V, Title II of the CNV Regulations. The Series XVI Notes have been authorized for listing on Bolsas y Mercados Buenos Aires S.A. (BYMA) through the Bolsa de Comercio de Buenos Aires S.A. (BCBA) and for trading on the A3 Mercados S.A. (A3). Legal advice to John Deere Credit Compañía Financiera S.A. O'Farrell: Partner Sebastián Luegmayer, Senior Consultant Nicolás Fernández Madero and associate Irupé Martínez. Legal advice to the Placement Agents EGFA Abogados: Partner Carolina Curzi and associates María Constanza Martella, Agustina Weil and Marina Galíndez.  

Following the enactment of Law N°27,739 on March 15, 2024, which designated the CNV as the regulatory authority for the crypto industry, the CNV issued General Resolution No. 994, which introduced a mandatory registry for Virtual Assets Service Providers (“VASPs”). On October 15, 2024, the CNV issued General Resolution No. 1025/2024, which proposed a comprehensive regulatory framework applicable to VASPs and opened a consultation process, which ended with the issuance of General Resolution No. 1058/2025 on March 12, 2025- The following is an overview of the key elements of the regulation: The VASPs Registry General Resolution No. 1058/2025 outlined the requirements and conditions for registration and the necessary documentation that both individuals and entities needed to submit to be included in the VASPs Registry. The regulation aimed to ensure proper oversight of VASPs and enhance regulatory compliance in line with anti-money laundering efforts. (a) Scope of the VASPs Registry The CNV's resolution established specific conditions for mandatory registration. Individuals and entities residing or established in Argentina who are directly engaged in VASP Services, are required to register in the VASPs Registry before conducting such activities. For foreign individuals and entities, the requirement to register applies if they perform VASP Services that are connected with Argentina. Registration is mandated if operations involve: (i) the use of a ".ar" domain, (ii) commercial agreements or subsidiaries receiving funds from Argentine residents for operations (ramp services), (iii) clear business focus or advertising directed at Argentine residents, not including cases where the client initiates contact with the legal entity established outside the Republic of Argentina (reverse solicitation), or (iv) a business volume in Argentina exceeding 20% of their total business volume (in which case only the total business volume related to the activities requiring registration in the VASPs Registry will be considered). Exemptions from registration are granted to VASPs if the total value of their activities or operations do not exceed the equivalent of 35,000 UVA per month (approx. US$44,275). In that regard, unregistered individuals and entities were prohibited from conducting VASP Services within Argentina. Foreign VASPs not registered in the VASPs Registry may participate as sponsors in international events held in Argentina, provided they meet certain conditions. (b) Disclosure requirements Registered entities are obligated to display a clear notice on their website, social media, and promotional materials indicating their registration status. This notice clarifies that registration was for oversight purposes only and does not imply licensing or supervision by the CNV over the VASP’s activities. Furthermore, registration in the VASPs Registry does not equate to a license to operate virtual asset activities, which will be subject to further regulation, as mentioned in section B. below. (c) Public offering of virtual assets The resolution clarifies that the CNV has the authority to exclusively regulate the activity of PSAVs, without extending such authority to the regulation of virtual assets, except when they fall under the definition of securities as established in Article 2 of Law No. 26,831. In that regard, PSAVs are prohibited from making any offering or intermediation that constitutes a public offering of virtual assets that qualify as securities, unless they have been granted public offering authorization by the CNV. However, the resolution lacks mechanisms to determine when a specified virtual asset is considered a security. (d) Effectiveness VASPs registered in the VASP Registry as of the effective date of General Resolution No. 1058/2025 (i.e., May 26, 2025), must comply with the following requirements: • VASPs must update and complete all documentation requested for the VASPs Registry, before July 1, 2025 (in the case of individuals), or before August 1, 2025 (in the case of entities). • VASPs organized as S.A.S. (simplified share companies), must convert to S.A. or S.R.L. types. • Foreign VASPs must prove their registration as a branch in Argentina (Article 118 of Law No. 19.550) before September 1, 2025. In cases where foreign VASPs decide to establish a company in the country (remaining as a foreign shareholder), the newly formed company must apply for registration in the VASP Registry before September 1, 2025. • All provisions established in the General Resolution 1058/2025, except for those specified in the preceding paragraphs, will be applicable to registered VASPs, starting on December 31, 2025. O’Farrell has a dedicated team of Virtual Assets laws and regulations lawyers, whose deal experience, business acumen, and regulatory insight can help guide clients through a wide range of sophisticated transactions and regulatory requirements. ayeeof.com.ar For more information contact: Sebastian Luegmayer Partner [email protected] Nicolas Fernández Madero Senior Counsel [email protected]