01 THE HOUR
Late evening
Sunday, October 27, 2019 / Buenos Aires
The presidential election had been called. Alberto Fernandez took 48.24 percent of the vote, above the threshold needed to win outright, and the Central Bank of the Republic of Argentina convened an emergency board meeting. Rumours of a bank holiday were circulating. The board ruled out a bank holiday and tightened the purchase limit on foreign currency that had been in force since September 1.
The new ceiling was announced before dawn on Monday. Individuals could now buy a maximum of 200 US dollars per month through a bank account, down from the 10,000 set eight weeks earlier.
02 THE SEQUENCE
Aug 11 The PASO primary. Fernandez and his running mate, former president Cristina Fernandez de Kirchner, took 47.7 percent of the vote. President Mauricio Macri received 32.1 percent, a margin far wider than any poll had projected.
Aug 12 Monday. The peso closed approximately 15 percent weaker, at around 53.5 per US dollar, having fallen as much as 30 percent intraday. The main stock index fell roughly 48 percent in dollar terms. Both moves were the largest single-day shifts in at least eighteen years.
Aug 28 Finance Minister Hernan Lacunza announced a unilateral extension of maturities on short-term local-law debt and a plan to renegotiate foreign-law bonds and the $57 billion IMF programme. He called it a "reprofiling."
Sep 1 A Sunday. Executive Decree 609/2019 was published in the Official Gazette, reinstating foreign exchange controls that had been abolished in December 2015. The BCRA issued Communication A 6770 the same day. Companies now required prior central bank approval to buy foreign currency to build up foreign assets, make early repayment of debts, and transfer earnings and dividends abroad. Individuals could still buy up to 10,000 US dollars a month without approval. Exporters were ordered to repatriate proceeds within five business days for shipments registered before September 2, and within fifteen or 180 calendar days for new shipments.
Sep 2-3 The depreciation from Monday to Tuesday was 0.14 percent. The controls had, for the moment, stopped the slide.
Week of Oct 21 Ahead of the presidential election, depositors moved to buy dollars and withdraw existing dollar deposits from banks.
Oct 28 Communication A 6815. The purchase limit dropped from 10,000 to 200 dollars per month through a bank account. Cash purchases were capped at 100 dollars per month. The BCRA stated these limits were not cumulative: the total was 200, of which 100 at most could be in physical notes. Central bank governor Guido Sandleris held a press conference at 8:30 that morning to explain the measures.
By late Oct Private-sector dollar deposits in the banking system stood at 19.1 billion dollars, 10.6 percent below the end-of-September level. The BCRA's Financial Stability Report noted that foreign currency deposits had fallen by approximately one third from their pre-PASO level by the end of September. International reserves had lost nearly 23 billion dollars in total and stood at 43.5 billion.

America’s new money

Something strange is happening to your money.

It wasn't voted on. It wasn't debated in the Senate. And most Americans have no idea it's even taking place but…

President Trump is replacing the U.S. dollar.

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Which side will you be on?

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03 THE HIDDEN DEPENDENCY
The cepo restricted the channel through which pesos could be converted into dollars. It did not restrict the withdrawal of dollars already held. Depositors who had dollar-denominated savings accounts could still take their dollars out, and the banking system met the demand: the BCRA's own reporting described the system as operating without disruption, with liquidity buffers absorbing the drawdown.
The operational question was not whether existing balances were reachable. It was whether pesos could still be turned into dollars at all, and at what price. When the official purchase window was capped at 200 dollars a month, any demand above that ceiling had to go somewhere else.
The operational question was not whether existing balances were reachable. It was whether pesos could still be turned into dollars at all, and at what price.
04 WHAT STILL WORKED
EXISTING DOLLAR DEPOSITS
Dollar-denominated savings and checking accounts remained accessible. The BCRA's Financial Stability Report noted that the banking system absorbed the decline in foreign currency deposits with adequate liquidity. The restriction was on converting pesos to dollars, not on holding or withdrawing dollars already in the system.
PESO TRANSACTIONS
Domestic peso-denominated payments, card transactions, and interbank transfers continued to function. The controls applied to the foreign exchange market, not to the domestic payments infrastructure.
05 THE DOCUMENT
THE DOCUMENT
September 1, 2019
Decree 609/2019 was published in the Boletin Oficial on a Sunday, the same day the BCRA issued its implementing regulation, Communication A 6770. The decree reinstated the foreign exchange controls that President Macri had dismantled in December 2015, three years and eight months earlier. Its first article required that export proceeds be brought into the country in foreign currency and settled in the foreign exchange market. The BCRA communication set the deadlines: five business days for pre-existing shipments, fifteen or 180 calendar days for new ones.
06 THE PATTERN LIBRARY
#1
When one retail withdrawal channel closes or fails, demand concentrates on whichever channel is left open, and the capacity of that channel sets what a depositor can obtain.
Observed: Northern Rock 2007, Cyprus 2013, India 2016, Greece 2015, United States 1933, Argentina 2001, Lebanon 2019, Worldpay 2026, TSB 2018, Afghanistan 2021, Nigeria 2023, Square 2023, United States 2025, Fiserv 2025, United States 2021, RBS Group 2012, Soviet Union 1991, Russia 2022.
#4
Domestic payment channels can continue while cross-border wire transfer routes fail. Where credit card settlement runs through a separate institution on an independent network, it may persist after the wire transfer channel closes. In some cases the central bank intermediates selected transfers through its own remaining correspondent accounts.
Observed: Iceland 2008, Germany 1931, Belize 2015, Russia 2022.
#9
A payment outage can hit card authorisation and merchant funding as separate faults, so acceptance at the terminal is restored while the money owed to the merchant arrives a day late under its own incident notice.
Observed: Worldpay 2026, United States 2021, Marqeta 2026, Square 2023.
#17
One foreign currency can carry more than one price at the same moment inside a single country, the authority setting them by the use the money is put to or by the date a balance was credited, while another price goes on being made outside the official ones.
Observed: Lebanon 2019, Mexico 1982, Egypt 2016, Argentina 2019.
#37
A foreign currency purchase limit can cap the conversion channel while leaving existing foreign currency deposits withdrawable, so the restriction falls on acquiring the currency rather than on holding it, and the banking system meets withdrawal demand from its own liquidity buffers.
Observed: Argentina 2019.
CHANGED TODAY:
Entry 17 gained Argentina 2019. New entry 37 added, on the purchase limit as distinct from a deposit freeze.