An agro-industrial company from Santa Cruz exports soy, gets paid late, and finances each campaign with increasingly expensive local credit. It wants to raise private capital with a tokenized instrument and the starting point is twofold: Bolivia lifted in June 2024 the ban on operating with crypto-assets, but still lacks a framework for tokenized securities.
Bolivia's opening is one of the fastest regulatory shifts in the region, and even so it does not solve the issuer's problem. This guide separates what the new regulation allows from what does not yet exist, explains why de facto dollarization conditions any local fundraising, and details when it is advisable to issue a security token under the European framework from Spain.
What framework exists today in Bolivia
Until 2024, Bolivia maintained one of the most restrictive positions in Latin America: since 2014 the Central Bank prohibited the use of crypto-assets in the payment system. That veto fell in June 2024, when the BCB enabled, through a board resolution, electronic payment channels and instruments to buy and sell virtual assets. The shift responded less to a technological bet than to the currency crisis: with scarce dollars, closing the door to crypto-assets had ceased to be sustainable.
In 2025 came the second phase. Two supreme decrees assigned to the Financial System Supervisory Authority (ASFI) the regulation of virtual asset service providers and the fintech sector, and ASFI issued its first guidelines in mid-year, with a provider registry whose registration deadlines have been extended. Volume followed: virtual asset transactions multiplied in the first year after the opening, according to official figures.
What is missing is as relevant as what exists. Bolivian securities market regulations do not contemplate the representation of securities on distributed ledger technology, ASFI does not have a registry figure comparable to the Spanish ERIR, and no channel currently enables a public offering of tokenized securities. The 2024 and 2025 opening regulates payment and intermediaries, not capital raising: a token that represents debt or equity is a security and returns to the general regime, designed for traditional instruments.
De facto dollarization conditions local fundraising
The second structural fact is monetary. The chronic scarcity of dollars has led companies and individuals to protect value in stablecoins and to reference contracts to the dollar even when they are settled in bolivianos. It is a de facto dollarization: it is not in the law, but it governs the prices of almost any relevant transaction, from a commercial lease to a machinery sale.
For an issuer, this has a direct reading. Raising funds locally in bolivianos forces the investor to assume an exchange rate risk they do not control, and raising funds locally in dollars clashes with the very scarcity that caused the problem. The capital the company needs is usually outside, in dollars or euros, and the right question is not only with what technology to issue but under what framework that capital can enter with legal certainty. It is a different situation from that of Ecuador, de jure dollarized, and more similar to the one that pushed issuers from Argentina to look at structures abroad.
When the European route makes sense from Bolivia
For the Bolivian issuer with export income, agroindustry, non-state mining, energy or services with international clients, the practical alternative is to issue under a framework that already recognizes tokenized securities. Spain has done so since 2023: Ley 6/2023 allows the representation of transferable securities through DLT-based systems, and its article 8 creates the entity responsible for registration and registry (ERIR), developed by Real Decreto 814/2023. The first authorized ERIR was URSUS-3 Capital, A.V., in November 2024, and the registry of ERIRs in Spain has continued to add entities.
The entry cost has also fallen. Since 5 June 2026, following the Listing Act, offerings of up to 12 million euros over 12 months are exempt from a prospectus, which puts a first issuance within reach of a mid-sized company. And classifying the instrument is no longer ambiguous territory: ESMA guidelines on cryptoassets as financial instruments, applicable since May 2025, set out which tokens are securities, and the MiCA regulation expressly excludes financial instruments from its scope (Article 2.4). A security token is governed by European securities rules, not by cryptoasset rules.
For the Bolivian case, the European route provides more than a framework: it provides the currency. Issuing from a Spanish vehicle makes it possible to raise euros from investors across the EU, with the token registered and supervised and without depending on the availability of foreign currency in the local market. The trade-off is real: it requires setting up a structure in Europe, coordinating advisers from both jurisdictions and carefully reviewing the Bolivian exchange-control and corporate regime applicable to the relationship between the local operations and the issuing vehicle. For small domestic raises, that cost does not pay off.
There is also a timing factor. Bolivian regulation is under construction: the 2025 decrees anticipate further regulatory development, and it cannot be ruled out that in a few years a local regime for tokenized securities will exist. But an issuer that needs capital in 2026 cannot plan around rules that do not yet exist. Issuing today under the Spanish framework does not close the door to operating tomorrow under a Bolivian framework: structures can coexist, and the experience of a first regulated issuance is often the best asset when the local market matures.
Bolivian framework and European route, head to head
| Criterion | Bolivia | European route (Spain) |
|---|---|---|
| Tokenized securities regime | Does not exist; the 2024-2025 opening covers payments and providers | Ley 6/2023 and RD 814/2023, with express recognition |
| Supervisor | ASFI (virtual asset providers and securities market) | CNMV |
| Token registration | No equivalent figure | ERIR (art. 8 of Ley 6/2023) |
| Offering documentation | General public offering regime, without DLT adaptation | Exemption up to 12 M€ in 12 months; CNMV prospectus above that |
| Investors reached | Local market, with foreign-currency restrictions | European Union |
| Fundraising currency | Boliviano, with de facto dollarization of contracts | Euro |
Process from Bolivia, step by step
- Classify the asset and the token. Determine, using the criteria of the ESMA guidelines, whether what is going to be issued is a transferable security. Debt, equity and profit rights almost always are.
- Structure the issuing vehicle. The usual approach is a Spanish company or another EU company that channels the asset or the cash flows of the Bolivian project and acts as issuer. The relationship between that company and the local operations, including the exchange-control regime applicable to the repatriation of funds, is documented with advisers from both jurisdictions.
- Prepare the offer documentation. Up to 12 million euros over 12 months no prospectus is required; above that, a prospectus approved by the CNMV under the European Prospectus Regulation.
- Appoint the ERIR. An entity from the CNMV registry handles the registration and recording of the tokenized securities. It is the differential requirement of the Spanish system.
- Issue and distribute. Technical deployment of the token, investor onboarding with KYC and anti-money laundering prevention, and communication of the offering within the limits of the applicable regime. A technology platform covers this layer; reserved functions correspond to registered or authorized entities.
The full process is detailed in the guide on how to issue a security token in Spain, and the regional comparison, country by country, in the tokenization for Latin American issuers hub.
Does your Bolivian company need to raise capital outside the country? Take the issuance diagnostic (2 min) or request a proposal. If you prefer to start by reading, download the 2026 guide.
This content is informative and educational. It does not constitute legal, tax, or investment advice. Check the current version of each regulation in the BOE and on EUR-Lex.
HokenFi is a software and infrastructure provider; it does not provide regulated services (CASP, ESI, EAF, or ERIR). This article is informative and does not constitute financial or legal advice.
Frequently asked questions
Are cryptoassets allowed in Bolivia?
Yes, since June 2024, when the Central Bank of Bolivia lifted the prohibition in force since 2014 and enabled electronic payment channels for operating with virtual assets. In 2025, two supreme decrees assigned ASFI the regulation of providers of these services, with a mandatory register whose deadlines have been extended repeatedly.
Can a company issue security tokens under Bolivian regulation?
There is no specific route. The 2024 and 2025 opening regulates payments with virtual assets and service providers, not capital raising. A token that represents debt or equity is a security and would be subject to the general securities market regime, which does not contemplate representation on DLT or a registration figure such as the ERIR.
How does a Bolivian company raise euros from investors?
The usual structure is an issuing vehicle in Spain or another EU Member State that channels the asset or the cash flows of the Bolivian project. The issuance is governed by Ley 6/2023, with the securities registered by an ERIR and, since June 2026, the prospectus exemption for offerings of up to 12 million euros over 12 months.
