Costa Rica Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): General Superintendency of Financial Institutions, General Directorate of Taxation, Central Bank
Primary Legislation: This is the fundamental AML/CFT law in Costa Rica., This is SUGEF's detailed regulation for implementing AML/CFT for various obligat, Law 7732, Proyecto de Ley para Regular las Actividades de Finanzas Descentralizadas (Finte, Art. 3 of Decree No. 26761
Travel Rule: Adopted — Threshold: $1,000
Tax Reporting: If cryptocurrencies are considered movable assets or intangible goods for tax purposes in Costa Rica, capital gains tax may apply, but the specific treatment and determination of taxable gains must be derived from detailed local frameworks that account for all sources of income (including salary, dividends, and crypto) as they are continuously refined by regulatory authorities.. Rate: The standard capital gains tax rate in Costa Rica is 15%. This applies to gains realized from the sale of shares, real estate, and other movable assets, provided it is not part of a habitual commercial activity.. Losses: Capital losses can generally be offset against capital gains from the same type of assets.. Income tax applies to crypto activities in Costa Rica; as of 2025, Executive Decree Nº 44772-H broadens taxable income for certain entities, potentially eliminating the prior habitual-activity vs. mere-investment distinction for those entities, though the old distinction may still apply to individuals not covered by the decree.. Mining: If an individual or business performs cryptocurrency mining as a regular, profit-seeking activity within Costa Rica, the income generated from mining would likely be subject to standard income tax rates.

Key Facts

aml Law No. 7786, "Law on Narcotics, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Money Laundering and Financing of Terrorism" (Ley sobre Estupefacientes, Sustancias Psicotrópicas, Drogas de Uso No Autorizado, Actividades Conexas, Legitimación de Capitales y Financiamiento al Terrorismo), as amended. This is Costa Rica's foundational AML/CFT law. Law No. 10.363, "Law on the Regulation of Virtual Asset Service Providers" (Ley de Regulación de Proveedores de Servicios de Activos Virtuales). This law established the legal framework for VASPs, bringing them under Law 7786's AML/CFT scope. However, the operational AML/CFT obligations and registration mandate became enforceable only after SUGEF's implementing regulation (SUGEF 2-2024) came into effect on November 16, 2024. Regulations issued by SUGEF: While Law 10.363 sets the legal framework, the Superintendent General of Financial Entities (SUGEF) is responsible for developing specific regulations. The key implementing regulation, SUGEF 2-2024 ("Reglamento para la Inscripción y Supervisión de los Proveedores de Servicios de Activos Virtuales"), was issued and became effective on November 16, 2024. It details registration, CDD, transaction monitoring, STR, and record-keeping requirements for VASPs. Physical residential address Identification number (e.g., national ID card, passport number) Contact information (e.g., phone number, email address) Source of funds/wealth (as part of Enhanced Due Diligence (EDD) for high-risk clients, which may include scrutiny of large transactions as a contributing factor to the risk assessment). Verification through reliable, independent source documents, data, or information (e.g., government-issued ID, utility bills).
enforcement Regulator Name: Superintendencia General de Entidades Financieras (SUGEF) The targeted entities under Costa Rica's enforcement framework are now specifically regulated financial institutions and registered Virtual Asset Service Providers (VASPs), rather than the general public or anyone implicitly operating with virtual assets. Violation Type: N/A (This is a regulatory clarification, not an enforcement action for a violation). However, financial institutions are warned about the risks of dealing with unregulated entities or engaging in unregulated activities. Penalty Amount: N/A. Date: Ongoing, with several specific real-world developments and escalating crises (e.g., political clashes, alignment with Trump, structural violence) rather than general communiques. September 2021: SUGEF Circular SGF-0036-2021 reiterates that virtual assets are not legal tender and are not regulated by SUGEF unless they fall under existing regulated activities. January 2022: SUGEF continues to issue warnings regarding the risks of virtual assets. Outcome: SUGEF maintains that virtual assets are not regulated financial products or services under its supervision. Financial institutions are advised to exercise extreme caution when dealing with virtual assets and to ensure compliance with existing AML/CFT regulations if handling any related transactions. This means that if a bank facilitates transactions involving crypto, it must still comply with its existing AML obligations. SUGEF Official Website (communiques are often published here, though direct links to specific circulars can be hard to maintain as websites update): https://www.sugef.fi.cr/
general The Banco Central de Costa Rica (BCCR) is an active regulatory authority that also engages directly in market intervention to manage the exchange rate and stabilize the colón, as evidenced by its record dollar-buying and public warnings from its president about currency shifts. Role: Primarily responsible for monetary policy and financial stability. The BCCR has consistently stated that cryptocurrencies are not legal tender in Costa Rica and do not have the backing of the Central Bank. They have issued several warnings to the public and financial institutions about the risks associated with virtual assets. Official Website: https://www.bccr.fi.cr/ Relevant Statement (Example - 2017, reaffirmed multiple times): While specific direct URLs to recent reaffirmations can be ephemeral, the BCCR's consistent stance since 2017 has been clear. An example of their communication is "Banco Central reitera advertencias sobre monedas virtuales y sus riesgos," which although from 2017, established the core position. This position is frequently reiterated in public communications. Role: Oversees regulated financial entities (banks, credit unions, etc.). While SUGEF does not regulate crypto activities directly (as there's no specific law for it), it has issued warnings about the risks associated with virtual assets and has clarified that financial institutions under its supervision cannot offer services involving virtual assets as part of their regulated activities without specific authorization, which currently doesn't exist. It also emphasizes that existing Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws apply to any entity falling under its purview that might interact with crypto. Official Website: https://www.sugef.fi.cr/ Relevant Statement (Example): SUGEF has issued circulars and communications to regulated entities outlining the risks and stating that entities under its supervision cannot engage in crypto activities without explicit regulatory approval. For instance, Circular SUGEF 002-2017 (later updated) generally advises regulated entities on potential risks. Law 7786: Ley sobre estupefacientes, sustancias psicotrópicas, drogas de uso no autorizado, actividades conexas, legitimación de capitales y financiamiento al terrorismo (Law on Narcotics, Psychotropic Substances, Unauthorized Drugs, Related Activities, Money Laundering and Terrorist Financing), dated 1997 (with subsequent reforms).
licensing Superintendencia General de Entidades Financieras (SUGEF): The General Superintendency of Financial Institutions. SUGEF is responsible for supervising financial entities and enforcing AML/CFT regulations for many obligated subjects. Virtual asset service providers in Costa Rica are not yet explicitly classified as 'obligated subjects' under Law 7786; the proposed amendment (Expediente 22.837) that would explicitly include them remains pending and has faced procedural setbacks. Registration: With SUGEF as an "obligated subject" (if the activity falls under their scope) or potentially with the Financial Intelligence Unit (Unidad de Inteligencia Financiera - UIF) depending on the exact classification. Full AML/KYC Program: Implementation of robust Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Transaction Monitoring policies and procedures. AML Officer: Appointment of a designated AML Compliance Officer. Reporting: Obligation to report suspicious transactions (SARs/STRs) to the UIF. Maintenance of transaction and client records for a specified period is now predominantly governed by electronic invoicing systems and specific monthly reporting obligations to the General Directorate of Taxation, fundamentally altering the methods and specific requirements for record-keeping in Costa Rica. Conduct a comprehensive money laundering risk assessment.
sanctions Requirement: As a member state of the United Nations, Costa Rica is legally bound to implement sanctions resolutions adopted by the UN Security Council under Chapter VII of the UN Charter. This includes asset freezes, travel bans, arms embargoes, and other targeted measures against designated individuals, entities, and countries. While previous guidance indicated that VASPs in Costa Rica with direct or indirect dealings with the U.S. financial system, U.S. persons, or U.S.-origin technology should screen customers and transactions against OFAC's Specially Designated Nationals (SDN) and Blocked Persons List, the forthcoming comprehensive VASP Law (expected July 2025) for Costa Rica does not explicitly include a mandate for screening against OFAC's lists. UN Security Council Resolutions: Various resolutions, e.g., those establishing sanctions regimes for specific countries (DPRK, Iran, etc.) or terrorist groups (Al-Qaida, ISIS). UN Consolidated Sanctions List: https://www.un.org/securitycouncil/content/un-sc-consolidated-list Requirement: While OFAC sanctions are primarily extra-territorial U.S. law, their global reach means that any VASP or financial entity operating internationally, interacting with U.S. persons, or using U.S. dollar infrastructure, must consider OFAC compliance. Failure to do so can lead to severe penalties, even for non-U.S. entities. OFAC Sanctions Programs and Country Information: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-country-information OFAC SDN List: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-country-information/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists Requirement: Similar to OFAC, EU sanctions (e.g., asset freezes, restrictions on financial transactions) have a significant impact globally, especially for entities dealing with EU persons, entities, or operating within the EU's sphere of influence.
securities The Superintendencia de los Sistemas de Pago (SUGEF) is the primary regulator overseeing financial payment systems, including virtual asset services. Costa Rica introduces a VASP framework Law 7786 (originally enacted in 1998, not 2019) established the initial AML/CFT framework in Costa Rica. As of May 2026, a reform explicitly incorporates virtual asset service providers (VASPs) as obligated subjects under this law, requiring SUGEF registration for AML/CFT supervision without a licensing regime. Thus, Law 7786 remains the foundational AML/CFT law, but the 2026 reform significantly expands its scope to VASPs. Law 10961 of 2022 further refined VASP obligations, including beneficial ownership reporting under the Registro de Títulos y Beneficiarios Financieros (RTBF). Costa Rica Crypto Regulation 2026: Law 10961 VASP Costa Rica is a member of GAFILAT (FATF-style regional body), not the FATF itself. Its June 2026 Law 10961 incorporated VASPs into its AML/CFT framework under SUGEF registration and supervision (without licensing), with obligations aligned with FATF standards. Who Needs a License: Virtual Asset Service Providers (VASPs) such as exchanges, wallets, and trading platforms are subject to registration but not formal licensing by SUGEF. Costa Rica Cryptocurrency Regulations: Requirements for ... Activities Requiring Registration: Trading, exchanging, and custodial services for virtual assets fall under registration obligations. No capital thresholds are explicitly set, but compliance with AML/CFT and beneficial ownership disclosures is mandatory. Costa Rica Crypto Regulation 2026: Law 10961 VASP Application Process: Registration involves submitting an application to SUGEF, providing KYC/AML documentation, and filing beneficial ownership information through the RTBF. No timeline is specified in the law, but the process is expected to be prompt upon submission. Costa Rica introduces a VASP framework Entities must be legally registered in Costa Rica and maintain operational infrastructure compliant with SUGEF guidelines. As of late June 2026, Costa Rica is transitioning from a de facto registration-based approach to a formal VASP framework under Law 25.340, which was passed by the Legislative Assembly on 27 May 2026 and awaits presidential signature; the framework establishes a 'first-stage regulatory approach' rather than a full licensing regime.
status Regulatory Body: Superintendencia de Instituciones Monetarias y Financieras (SIF) – responsible for overseeing banking, insurance, securities, and payment institutions. Website: https://www.sif.go.cr/ Primary Law: Ley General de Instituciones Financieras (LGIF) – enacted in 2010; regulates financial entities but does not explicitly mention cryptocurrencies. Article references are broad, covering “tasa de cambio y servicios financieros” that could be interpreted to include digital assets. International Standing: Costa Rica is a member of the Financial Action Task Force (FATF). The country aligns with FATF recommendations on virtual asset service providers (VASPs) and AML/KYC obligations, though no dedicated legislation yet formalizes these as distinct entities. Who Needs a License? Entities providing crypto-related services that involve payment processing, custodial functions, or act as intermediaries between fiat and digital assets may need to comply with existing financial licensing requirements under SIF. Activities Requiring Licensing: Money transmission (Art. 3 of Decree No. 26761), broker-dealer activities, and virtual asset services if classified as payment institutions. Capital Requirements: Not explicitly defined for crypto-specific licenses; however, money transmitters must maintain minimum capital as per SIF guidelines, typically USD $10,000–$50,000 depending on the type of service. Application Process & Timeline: Applications are submitted to SIF through their online portal. Processing can take 60–90 days for standard approvals, longer if additional due diligence is required. Structural Requirements: Entities must provide AML/KYC procedures, maintain records for at least five years, and ensure physical presence or authorized representation in Costa Rica.
tax If cryptocurrencies are considered movable assets or intangible goods for tax purposes in Costa Rica, capital gains tax may apply, but the specific treatment and determination of taxable gains must be derived from detailed local frameworks that account for all sources of income (including salary, dividends, and crypto) as they are continuously refined by regulatory authorities. Rate: The standard capital gains tax rate in Costa Rica is 15%. This applies to gains realized from the sale of shares, real estate, and other movable assets, provided it is not part of a habitual commercial activity. Losses: Capital losses can generally be offset against capital gains from the same type of assets. Income tax applies to crypto activities in Costa Rica; as of 2025, Executive Decree Nº 44772-H broadens taxable income for certain entities, potentially eliminating the prior habitual-activity vs. mere-investment distinction for those entities, though the old distinction may still apply to individuals not covered by the decree. Mining: If an individual or business performs cryptocurrency mining as a regular, profit-seeking activity within Costa Rica, the income generated from mining would likely be subject to standard income tax rates. Trading as a Business: If an individual or entity engages in frequent and systematic buying and selling of cryptocurrencies with the intent to profit, and this activity is deemed a commercial enterprise, the profits would be treated as business income. Staking Rewards, Lending Interest, DeFi Yields: If these activities are carried out habitually and professionally within Costa Rica, the proceeds could be considered taxable income. Receiving Crypto as Payment for Goods/Services: If a business or individual receives cryptocurrency as payment for goods sold or services rendered within Costa Rica, the fair market value of the crypto at the time of receipt would be considered taxable income and would be subject to income tax.
travel rule SUGEF Circular 001-2022 "Reglamento para la Inscripción y Supervisión de los Proveedores de Servicios de Activos Virtuales" (Regulation for the Registration and Supervision of Virtual Asset Service Providers). This circular directly addresses the registration and AML/CFT obligations of VASPs, including requirements for information sharing consistent with the Travel Rule. It was published in La Gaceta, the official Costa Rican government gazette. Collection of Information (Art. 24): VASPs must obtain and maintain information on the originator and beneficiary for all virtual asset transfers equal to or greater than USD $1,000 (or its equivalent in other currencies or virtual assets), regardless of whether the other party is another VASP or an unhosted wallet. For transfers below this amount, only basic information (e.g., name of the client) is typically required. Transmission of Information (Art. 25): For virtual asset transfers equal to or greater than USD $1,000 (or its equivalent in other currencies or virtual assets) to another regulated VASP, the sending VASP must securely transmit the required originator and beneficiary information to the receiving VASP. For transfers to or from unhosted wallets, the VASP is responsible for collecting and retaining the information from its own customer, but cannot transmit information to an unhosted wallet directly. Exchange between virtual assets and fiat currencies. Exchange between one or more forms of virtual assets. Transfer of virtual assets. Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-06. View full profile