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title: "Costa Rica Crypto Regulation Monitor | cryptoassets.gi"
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description: "Costa Rica crypto asset regulation: 8 categories, 36 sourced findings, updated 2026-10-25. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# Costa Rica Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed unregulated gap overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/costa-rica/)

Last updated 2026-10-25 · 8 categories · 36 sourced
findings · 29 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-10-25 · Position last changed: 2026-10-25 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

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Framework posture Unregulated gap 7 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority CoinDesk Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 CONASSIF implementing regulation for VASP AML regime finalisation

Module coverage & confidence 7 / 9 modules assessed 0 Confirmed · 7 Probable · 0 Uncertain · 2 Not yet assessed

8 Categories

0 Moved this cycle 0 Key judgments 3 Open gaps 36 Findings

3 Tier-1 sources

Confidence mix 8 unpopulated
(sums to 8 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 25 October 2026

#### Lead Signal

Costa Rica brought virtual asset service providers within a formal AML/CTF registration perimeter for the first time, following the entry into force on 19 September 2026 of Article 15 quater of Law 7786, added by Law 10961. The provision requires providers of exchange, custody, transfer, and issuance or offer services involving virtual assets to register with SUGEF, the national financial supervisor, for AML/CFT supervisory purposes. This statutory trigger is confirmed directly from the official gazette text. In early October 2026, the National Council for Financial System Supervision opened a public consultation on a draft amendment to Acuerdo SUGEF 13-19 that would give the registration requirement operational content: risk-based customer due diligence, new-product and new-technology risk assessment, and suspicious-transaction reporting duties. The content of that draft is currently known only through secondary press reporting rather than the consultation text itself, so its precise shape is probable rather than settled.

Commentary accompanying the underlying law has been explicit on an important limiting point: SUGEF registration does not constitute an operating permit, authorisation, or government endorsement. This leaves Costa Rica in a structurally unusual position for the region -- an AML registration gateway now exists and is being actively operationalised, but no licensing, custody-segregation, or market-conduct regime sits alongside it. The registration gateway is, at present, the only formal regulatory contact point a virtual asset provider has in the jurisdiction.

#### Other Developments

The draft SUGEF 13-19 amendment also touches cross-border exposure. Secondary reporting on the consultation indicates that registered providers would be required, as part of a broader new-product and new-technology risk assessment duty, to evaluate cross-border-operation risk and unhosted-wallet risk. This would be the first Costa Rica-specific articulation of a travel-rule-adjacent obligation for virtual asset activity, though it remains at the consultation stage and is not yet in force. The underlying risk-assessment framework it would sit within is the same one proposed for customer due diligence and suspicious-transaction reporting more broadly, so its fate is tied to the same consultation timeline.

Industry commentary has also flagged procedural uncertainty around the consultation itself. Reporting describes a short consultation window and unresolved questions concerning the criteria for appointing a compliance officer at registered providers. Neither the consultation's closing date nor an expected adoption date has been independently confirmed from a primary source; the draft amendment text and the National Council's session minutes were not directly retrieved.

#### Cross-Monitor Connections

The same registration requirement and consultation are material to financial-crime-focused tracking of Costa Rica, since the Article 15 quater AML gateway is currently the sole formal supervisory touchpoint for virtual asset activity in the jurisdiction, in the continued absence of any licensing or consumer-protection regime. Readers tracking money-laundering and terrorist-financing exposure in Costa Rica should treat this development as the same underlying fact viewed from the financial-integrity angle: a long-standing supervisory gap for virtual assets, previously associated with a weak rating on international standards for new technologies, is being closed through the AML channel rather than through a dedicated market-authorisation regime.

#### Outlook

The consultation on the SUGEF 13-19 amendment remained open as of the most recent press reporting in late October 2026, with no confirmed closing date. Whether the final rule retains the cross-border and unhosted-wallet risk-assessment elements as currently described, and how the compliance-officer appointment criteria are ultimately resolved, are the two most consequential open questions for providers assessing their registration posture. Separately, Costa Rica's central bank position that virtual assets are not legal tender and fall outside central-bank regulation remains the backdrop against which this AML-only perimeter operates; no development altered that position, and no licensing, token-classification, or stablecoin-specific regime has emerged alongside the AML registration gateway.

4 earlier updates not shown here.

###### Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Costa Rica's virtual-asset sector crossed a structural threshold this cycle: Legislative Decree No. 10961, inserting Article 15 quater into Law No. 7786 and published in La Gaceta on 19 June 2026, brings virtual-asset service providers into a mandatory AML/CFT registration regime supervised by SUGEF. The reform is explicit that registration does not constitute an operating licence — Costa Rican companies may still incorporate with cryptocurrency activities in their bylaws without a government-issued VASP licence, formal capital requirements, or business-model pre-approval. This is best read as a supervisory-perimeter expansion closing a FATF Recommendation 15 gap, not as the creation of a licensing regime for the underlying activity.

#### Other Developments

Cross-border transfer obligations tighten alongside registration. The same reform requires SUGEF-registered VASPs to implement customer due diligence, transaction record-keeping, and suspicious-transaction reporting — including attempted-but-failed transactions — to the ICD financial intelligence unit. These obligations reach cross-border transfers as a matter of course, though no explicit travel-rule provision was independently confirmed this cycle, leaving a meaningful information gap for any operator relying on Costa Rica as a transfer corridor.

Incorporation permissiveness persists, under pressure. Costa Rica continues to permit incorporation of a company with cryptocurrency activities named in its bylaws without a government-issued VASP licence, without formal capital requirements, and without mandatory regulatory pre-approval — a standing structural condition now under increasing legislative pressure as the AML/CFT registration regime layers on top of it. Whether this permissive incorporation posture survives the SUGEF implementing-regulation process in its current form is one of the more consequential open questions carried into next cycle.

Implementing regulations remain pending. SUGEF implementing regulations operationalising the registration mandate are expected within roughly three months of the 19 June 2026 gazette publication. Until they issue, the practical mechanics of registration, CDD thresholds, and reporting format remain unsettled, and this cycle's record cannot confirm whether they will extend into activity-level licensing or capital requirements.

#### Cross-Monitor Connections

This cycle's crypto_licensing and cross_border_transfer findings share their evidentiary root with the financial-integrity monitor's own D5 (Crypto, Digital Assets, and Financial Innovation) tracking of the identical Article 15 quater / Decree 10961 reform. Where this monitor frames the reform as a licensing question — registration without licensing — financial-integrity frames the same reform as closing a structural FATF R.15 gap. Neither framing supersedes the other; they are the same underlying development read through two different analytical lenses, and a reader following both monitors should expect the facts to match even where the emphasis differs.

#### Outlook

The SUGEF implementing regulations expected in the fourth quarter of 2026 are the single most consequential near-term development to watch: their content will determine whether Costa Rica's registration-only regime evolves toward an activity-licensing framework, and whether an explicit travel-rule mechanism is introduced for cross-border VASP transfers. Until they issue, both this cycle's findings should be treated as provisional rather than settled.

Read full brief · 1113 words

Key regulatory facts for Costa Rica Regulatory Dimension Costa Rica Standing Position

Jurisdiction Costa Rica (CR)

Regulatory Scope Crypto & Digital Asset Regulation (8 modules, 36 sourced findings)

Crypto Licensing Costa Rica has no crypto-asset operating licence.

Token Classification Costa Rica has no statutory token taxonomy.

On-Chain Activity Regime No Costa Rican law or regulation specifically addresses on-chain activities such as staking, DeFi lending, DEX operation, mining, node operation, validating, or tokenization.

Stablecoin Regime Costa Rica has no stablecoin-specific legislation covering issuance authorisation, reserve requirements, redemption rights, disclosure, or systemic designation.

Primary Instruments Cited CoinDesk, CoinDesk, FATF / GAFILAT, SUGEF, Costa Rica

Last Confirmed / Updated 2026-10-25 (29 sources in cumulative register)

8 of 8 categories

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### Costa Rica: C1 Crypto LicensingRedEnacted in forceModule confidence: Probable▾

Costa Rica has no crypto-asset operating licence. Since 19 September 2026, Ley 10961 (adding Art. 15 quater to Ley 7786) requires VASP registration with SUGEF for AML/CFT supervision; CONASSIF implementing regulation remained unpublished as of 2 October 2026.

Open gap — crypto-int-1 CONASSIF session minutes and the draft SUGEF 13-19 amendment text were not directly retrieved this cycle; consultation closing date and expected adoption date were not confirmed. no under-indexing note recorded

Horizon · 2026-Q4 (± a quarter) SUGEF VASP implementing regulations expected Adopted, not yet in force · Tier 3 source

Horizon · 2026-Q3 (± six months) SUGEF VASP-registration deadline (reported) Adopted, not yet in force · Tier 4 source

Horizon · 2026-Q4 (± a quarter) CONASSIF implementing regulation for VASP registration thresholds Consultation · Tier 3 source

Horizon · 2026-Q4 (± a quarter) CONASSIF implementing regulation for VASP AML regime finalisation Consultation · Tier 3 source

Horizon · 2026-Q4 (± a quarter) CONASSIF implementing regulation for VASP registration (Ley 10961) Proposed · Tier 3 source

Horizon · 2026-Q4 (± a quarter) SUGEF 13-19 VASP AML amendment expected adoption Consultation · Tier 2 source

#### Crypto Licensing

Costa Rica moved this cycle from a position of no VASP-specific obligation whatsoever to mandatory AML/CFT registration, via Legislative Decree No. 10961 (Article 15 quater, Law No. 7786), published in La Gaceta on 19 June 2026. SUGEF is designated as the registering and supervising authority. The reform's own text is explicit that registration does not constitute an operating licence or government authorization of the underlying crypto-asset business — a distinction the interpreter record and this brief both preserve rather than collapse. In practice, this means a Costa Rican company can still incorporate with cryptocurrency activities named in its bylaws without a government-issued VASP licence, without formal capital requirements, and without regulatory pre-approval of its business model, even as it now faces a new AML/CFT registration duty once SUGEF's implementing regulations take effect.

This is best read as a supervisory-perimeter expansion rather than a licensing-regime creation. The reform closes a documented gap relative to FATF Recommendation 15 by bringing VASPs into an AML/CFT obligated-entity framework, but it leaves the more fundamental question of activity licensing — capital adequacy, fit-and-proper tests for principals, product-specific conduct rules — unaddressed. SUGEF implementing regulations are expected within roughly three months of the gazette publication; until those issue, the operational mechanics of the registration duty remain unsettled.

#### Outlook

The principal item to watch is whether SUGEF's implementing regulations, expected in the fourth quarter of 2026, extend beyond registration mechanics into any form of activity-level licensing or capital requirement. Until they issue, Costa Rica's crypto sector operates under a registration mandate without an accompanying licensing perimeter.

Read full sub-brief · 261 words Periodic update · new data 2026-10-25

#### Crypto Licensing

Costa Rica's licensing posture for virtual asset service providers shifted meaningfully, though the shift is better described as the arrival of an AML registration gateway than as the creation of a licensing regime. Article 15 quater of Law 7786, added by Law 10961 and in force since 19 September 2026, requires providers of virtual asset exchange, custody, transfer, and issuance or offer services to register with SUGEF for AML/CFT supervisory purposes. This statutory trigger is confirmed directly from the official gazette publication. In early October 2026, the National Council for Financial System Supervision opened a public consultation on a draft amendment to Acuerdo SUGEF 13-19 designed to operationalise that registration requirement with risk-based customer due diligence, new-product and new-technology risk assessment, and suspicious-transaction reporting duties. The substantive content of the draft, however, rests on secondary press reporting rather than direct access to the consultation text, so it should be read as probable rather than confirmed.

The critical qualifying fact, evidenced independently from commentary on the underlying law, is that SUGEF registration does not constitute an operating permit, authorisation, or government endorsement. This distinction matters because it means Costa Rica now has an AML contact point for virtual asset activity without having created any parallel mechanism for market entry, consumer protection, or custody standards. In effect, registration confers supervisory visibility to SUGEF without conferring market legitimacy to the registrant, a configuration that leaves the overall regime amber: tightening in its AML dimension but still structurally absent a licensing framework. Industry commentary around the consultation has also flagged a short consultation window and unresolved questions over the criteria for appointing a compliance officer at registered entities, both of which bear directly on how quickly and how completely providers can come into compliance once a final rule is adopted.

#### Outlook

The consultation remained open as of late October 2026 reporting, with no independently confirmed closing date or adoption timeline, and the draft amendment text itself was not directly retrieved. Whether the final rule preserves the risk-based due diligence and reporting duties broadly as described, and whether it resolves the compliance-officer appointment question flagged by industry commentary, will determine how substantial the registration regime proves in practice. Until the amendment is adopted and a primary text is available, the registration gateway should be understood as a developing AML control mechanism rather than as any form of licensing or market-authorisation regime, and providers should not treat SUGEF registration as conferring any operating legitimacy beyond AML supervisory contact.

4 earlier distinct update(s) Periodic update · new data 2026-10-18

#### Crypto Licensing

Costa Rica's crypto licensing architecture is governed by Article 15 quater of Ley 7786, added by Ley 10961, which entered into force on 19 September 2026. The provision requires any person conducting, as a business, the exchange, transfer, custody or administration of virtual assets, or the provision of financial services linked to their issuance, marketing or offer within Costa Rican territory, to register with SUGEF for AML/CFT supervision. This registration is explicitly not an operating authorisation: it establishes a supervisory relationship for AML/CFT purposes rather than granting a licence to conduct business. The duty is binding and currently in force.

The critical complication is implementation. As of 2 October 2026, the CONASSIF implementing regulation that would define the registration procedure, applicable thresholds, and fee structure had not been published, nor had CONASSIF opened the matter for public consultation. No registration form, platform, or defined registration window currently exists. The statutory duty is therefore live in the sense that the obligation to register is already binding, but operationally the mechanism for compliance is absent. This is a genuine implementation gap: a VASP operating in Costa Rica today is subject to a registration duty it has no concrete means of discharging.

No primary legislative text, such as the official Gazette publication or a SUGEF circular, was directly retrieved this cycle; the findings rest on converging Tier 3 law-firm commentary rather than a Tier 1 source. This should be read as a caveat on precision rather than a reason to doubt the substance of the finding, since multiple independent commentary sources converge on the same description of the registration duty and the implementation gap.

#### Outlook

The CONASSIF implementing regulation is anticipated during the fourth quarter of 2026, a quarter-level estimate that carries genuine uncertainty given that no consultation had opened as of early October. Until the regulation is published, the registration canon, procedural steps and supervisory fee amount remain unknown, and VASPs operating in Costa Rica remain in a position of holding a binding registration obligation without a defined means of compliance. This implementation gap is the single most important fact for any entity assessing its Costa Rican regulatory exposure in this area.

Periodic update · new data 2026-10-11

#### Crypto Licensing

Costa Rica's crypto licensing landscape shifted from a complete regulatory gap to a narrow AML registration perimeter with the entry into force of Ley 10961 on 19 September 2026. The law added article 15 quater to Ley 7786, requiring virtual-asset service providers to register with SUGEF for AML/CFT/CPF risk-based supervision. This is a confirmed, Tier-1-sourced statutory requirement. Critically, the law and its registration mechanism are framed explicitly as a supervision and compliance perimeter, not an operating authorisation: a VASP that registers with SUGEF obtains no licence to operate, no prudential status, and no conduct-of-business approval. The registration addresses money-laundering risk exposure alone.

Enforcement provisions accompany the new registration requirement. Secondary analysis reports fines between 5% and 50% of the transaction amount for certain breaches, alongside sanctions ranging from two to one hundred base salaries for other forms of non-compliance; this detail is probable rather than confirmed, resting on a Tier-3 legal-commentary source rather than the statutory penalty schedule itself. CONASSIF has since opened a public consultation, reported around 7 October 2026, on an implementing regulation intended to flesh out thresholds, scope, exclusions and technical requirements under article 15 quater; this detail is uncertain, since CONASSIF's own consultation document was not located this cycle and the reporting rests on a single Tier-3 press account.

The overall licensing picture, then, is one of a tightening AML perimeter sitting atop an otherwise unregulated activity: no token-classification-driven licensing tiers, no capital or prudential requirements, and no market-conduct supervision exist for virtual-asset activity in Costa Rica beyond the AML/CFT registration obligation itself.

#### Outlook

The CONASSIF implementing regulation is expected within the fourth quarter of 2026 as scheduled, carrying a quarter-wide uncertainty band given its basis in secondary reporting rather than a confirmed regulatory timetable. Until the regulation, or the underlying consultation document, is retrieved directly, the precise scope, thresholds, and exclusions of the registration regime remain provisional, while the underlying registration obligation itself stands confirmed and in force.

Periodic update · new data 2026-10-04

#### Crypto Licensing

Costa Rica's crypto-licensing landscape changed materially this cycle with the entry into force of Article 15 quater of Law 7786, added by Law N.246 10961 and published in La Gaceta Alcance N.246 78 on 19 June 2026. The provision requires any provider of virtual-asset exchange, transfer, custody or control, or issuance-related financial services to register with SUGEF before conducting that activity in Costa Rica. The statutory text is unambiguous that this registration does not constitute authorisation to operate -- it is a compliance gate built for AML/CFT purposes, not a prudential or conduct licence. The provision took effect roughly three months after publication, around 19 September 2026.

Penalties for breach of registration, customer-due-diligence or reporting obligations under amended Article 81 run from 5% to 50% of the transaction amount, or 2 to 100 base salaries, scaled to gravity and recidivism. This is a meaningful exposure for any VASP operating in or into Costa Rica without registering.

The open gap is CONASSIF's implementing regulation, due under Article 4 of Law 10961 within three months of entry into force -- meaning roughly December 2026 -- covering thresholds, scope, exclusions and technical requirements. That regulation has not been published as of this cycle, so the registration duty currently exists without published quantitative or technical detail, and secondary commentary (not yet confirmed against the gazette text) suggests VASPs may also be drawn into Costa Rica's existing RTBF beneficial-ownership filing regime with the Central Bank.

#### Outlook

The CONASSIF implementing regulation, expected in Q4 2026, is the development that will convert this statutory registration duty into an operative regime with defined thresholds and technical requirements. Until it publishes, the practical scope of who must register and under what conditions remains incompletely specified.

Periodic update · new data 2026-09-28

#### Crypto Licensing

Costa Rica's crypto-licensing landscape shifted this cycle with the introduction of a mandatory SUGEF registration requirement for virtual asset service providers, established under new Article 15 quater of Law No. 7786. This registration is explicitly for AML/CFT supervisory purposes only and does not constitute an operating licence or any form of government authorisation to conduct crypto-asset business. The distinction matters commercially: a VASP operating in Costa Rica can now become subject to AML/CFT obligations and SUGEF oversight without ever obtaining a substantive licence, because no such licence exists to obtain. Token issuance rules, custody standards, and exchange licensing all remain unregulated as of this reform; the 2026 change addresses AML/CFT registration only and leaves the broader licensing gap untouched.

This creates what the evidence characterises as an expanding AML/CFT perimeter running ahead of, and separate from, any expansion of substantive licensing perimeter. A firm can become AML-obligated while remaining functionally unlicensed, and current evidence suggests this gap is likely to persist absent further legislative action beyond the AML/CFT reform itself. Secondary sources report a registration deadline falling in the third quarter of 2026, though this has not been confirmed against a primary regulatory calendar, and whether Legislative Decree 10961 has actually been published in La Gaceta with that precise effective date remains an open question this cycle, with SUGEF's own domain not independently fetched.

#### Outlook

The near-term watch item is confirmation of the SUGEF registration deadline and the gazette-publication status of Legislative Decree 10961. Longer term, whether Costa Rica moves beyond AML/CFT registration toward a substantive licensing framework for crypto-asset businesses remains an open legislative question, with no current evidence of movement in that direction.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (11)
- T3[SUGEF](https://www.step.org/industry-news/costa-rican-government-introduces-vasp-framework) — VASPs must register with SUGEF for AML/CFT supervisory purposes; registration explicitly does not constitute an operating licence or government authorization.
- T3[Costa Rica](https://www.zitadelleag.com/news/where-to-register-a-vasp-company-without-licensing-costa-rica-and-panama) — Incorporation of a company with cryptocurrency activities in its bylaws without a government-issued VASP licence, formal capital requirements, or mandatory regulatory approval, though this status is under legislative pressure.
- T3[SUGEF](https://www.unknowngravity.com/en/articulos/asset-tokenization-in-costa-rica) — registration before offering virtual-asset exchange, transfer, custody/administration, or issuance-related financial services in Costa Rican territory
- T2[CONASSIF](https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/) — amendment to Acuerdo Sugef 13-19 adding VASPs as obliged subjects for client identification (reported threshold ~US$1,000), wallet-address attribution and suspicious-transaction reporting
- T3[CONASSIF implementing regulation (Ley 10961)](https://www.corporaciongc.com/articulos/costa-rica-vasp-registration-sugef) — The CONASSIF implementing regulation under Ley 10961, due within approximately three months of the law's entry into force, had not been published or placed under public consultation as of 2 October 2026; no registration window, form or platform yet exists.
- T1[SUGEF](https://www.imprentanacional.go.cr/pub/2026/06/19/ALCA78_19_06_2026.pdf) — VASPs (exchange, custody, transfer, issuance/offer services) must register for AML/CFT supervision, effective 19 Sept 2026
- T3[Ley 10961](https://josemoras.substack.com/p/la-sugef-empieza-a-vigilar-el-negocio) — SUGEF registration does not constitute an operating permit, authorisation or government endorsement.
- T2[CONASSIF](https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/) — Draft amendment to Acuerdo SUGEF 13-19 setting out risk-based KYC/CDD, new-product risk assessment and STR duties for registered VASPs; industry noted a short consultation window and unresolved compliance-officer appointment criteria.

### Costa Rica: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable▾

Costa Rica has no statutory token taxonomy. The Central Bank of Costa Rica (BCCR) has issued non-binding administrative interpretations: a 2017 communiqué stating that cryptocurrencies (including bitcoin) cannot be legal tender, and a 2019 report classifying cryptocurrencies as 'goods' or 'property' under the Civil Code rather than as money, currency, or a security.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-10-25

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### Costa Rica: C3 On-Chain Activity RegimeRedEnacted in forceModule confidence: Probable▾

No Costa Rican law or regulation specifically addresses on-chain activities such as staking, DeFi lending, DEX operation, mining, node operation, validating, or tokenization. Such activities fall under the general civil-code permissibility principle rather than a dedicated activity-specific regime; there is no analogous licensing or supervisory framework for any of these categories.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25

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### Costa Rica: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable▾

Costa Rica has no stablecoin-specific legislation covering issuance authorisation, reserve requirements, redemption rights, disclosure, or systemic designation. Stablecoins are treated, if at all, under the same general 'goods'/property classification the BCCR has applied to crypto-assets generally; no issuer authorisation or reserve regime exists.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) .

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### Costa Rica: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable▾

Costa Rica has no crypto-specific consumer-protection statute. Existing securities/fund regulation applies only when crypto exposure is wrapped in a recognized investment vehicle. In February 2025, state-owned Banco Nacional's asset-management arm, BN Fondos, launched a bitcoin exchange-traded fund because Costa Rican regulation does not permit funds to hold assets, such as bitcoin directly, that are not recognized investment vehicles; the ETF wrapper was used to satisfy existing fund rules rather than any bitcoin-specific consumer-protection framework.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded in this cycle

Sources and findings (1)
- T3[CoinDesk](https://www.coindesk.com/markets/2025/02/21/costa-rica-makes-first-foray-into-crypto-with-new-bitcoin-etf) — Costa Rican financial regulation does not permit investment funds to hold assets that are not recognized investment vehicles; because bitcoin itself is not classified as an investment vehicle, Banco Nacional's BN Fondos structured its bitcoin exposure through a regulated exchange-traded fund rather than direct bitcoin holdings in order to comply with existing fund rules.

### Costa Rica: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

Costa Rica has no dedicated crypto-asset tax statute. In an August 2023 private letter ruling, the Ministry of Hacienda (tax authority) determined that cryptocurrencies are 'virtual assets' for tax purposes and may be subject to corporate income tax or capital gains tax depending on the circumstances, and that crypto service providers such as wallet providers, miners, and exchanges must comply with various existing tax obligations.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 6 traced claims · Re-verified 2026-10-25

The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month , or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products) .

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### Costa Rica: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable▾

Costa Rica imposes no crypto-specific outbound restriction on cross-border transfers of virtual assets; absent dedicated legislation, such transfers are governed by the same general civil-code permissibility principle applicable to crypto-assets generally. FATF/GAFILAT follow-up reporting notes broader gaps in Costa Rica's identification and supervision of VASPs relevant to AML/CFT (including Travel Rule) implementation; that dimension is captured here only as disambiguation context, since AML/CFT-scope findings are covered under the crypto consumer's FIM aml_ctf subscription rather than in this baseline.

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Costa Rica has no in-force cross-border-transfer-specific rule for virtual assets, but the draft amendment to Acuerdo SUGEF 13-19 currently out for consultation would introduce the jurisdiction's first articulation of cross-border and counterparty-risk assessment obligations for registered virtual asset providers. According to secondary press reporting on the consultation, the draft would require providers to assess cross-border-operation risk and unhosted-wallet risk as part of a broader new-product and new-technology risk-evaluation duty tied to the Article 15 quater registration regime. This would sit alongside the risk-based customer due diligence and suspicious-transaction reporting obligations also proposed in the same draft, meaning cross-border risk assessment is not being introduced as a standalone travel-rule instrument but as one strand of a single consolidated AML risk-assessment framework.

The consultation-stage status of this obligation is an important qualifier: nothing in the current cross-border-transfer landscape is yet binding, and the draft text itself was not directly retrieved, so the precise scope of what counts as a cross-border operation, and how unhosted-wallet counterparties are to be treated under the assessment duty, remain open questions resting on secondary characterisation rather than primary drafting language. Industry commentary accompanying the consultation has noted a short consultation window and has not resolved related procedural questions, such as compliance-officer appointment criteria, that would bear on how providers operationalise any eventual cross-border risk-assessment duty.

#### Outlook

Whether the cross-border and unhosted-wallet risk-assessment elements survive into the final adopted version of the Acuerdo SUGEF 13-19 amendment, and in what form, is the central open question for this module going forward. No adoption date has been confirmed. Providers with cross-border virtual asset operations touching Costa Rica should treat the current absence of a binding cross-border rule as temporary rather than settled, given that the consultation already signals regulatory intent to extend risk-based scrutiny to cross-border and unhosted-wallet exposure once the broader VASP AML framework is finalised.

Periodic update · new data 2026-10-18

#### Cross-Border Transfer

Costa Rica's cross-border virtual-asset transfer regime is set out in Article 15 quater of Ley 7786, in force since 19 September 2026. The provision requires VASPs to obtain and retain originator and beneficiary information for both inbound and outbound virtual-asset transfers, in line with the FATF international standard commonly known as the Travel Rule. VASPs must make this information available to competent authorities on request and must apply controls equivalent to those already required for cross-border fiat-currency transfers. This is a binding duty currently in force, though the specific thresholds that will determine which transfers trigger the duty in practice remain dependent on the CONASSIF implementing regulation that had not been published as of 2 October 2026.

The same statutory provision imposes a sanctions-nexus duty: VASPs must adopt immediate freezing measures and are prohibited from transacting, in connection with virtual-asset transfers, with individuals or entities designated by international sanctioning bodies. This duty, too, is binding and in force since 19 September 2026, and operates independently of the pending threshold-setting regulation, since freezing and prohibition obligations do not depend on a transaction-size threshold in the same way the Travel Rule's practical scope does.

Taken together, the Travel Rule and sanctions-freezing duties represent a reasonably comprehensive statutory baseline for cross-border virtual-asset transfer compliance, aligned with the FATF standard in principle. The practical gap is the same one affecting the licensing module: the thresholds, technical specifications, and procedural detail that would make the Travel Rule duty operationally precise remain pending CONASSIF action.

#### Outlook

The threshold-setting CONASSIF regulation remains the single pending item that will determine the practical scope of the cross-border transfer obligations. Until it is published, expected in the fourth quarter of 2026 on a quarter-level estimate, VASPs face a binding Travel Rule and sanctions-freezing duty whose precise transactional scope is not yet defined. Firms engaged in cross-border virtual-asset transfers involving Costa Rica should treat the current statutory baseline as the operative standard while anticipating further technical specification once the implementing regulation is published.

Periodic update · new data 2026-10-11

#### Cross-Border Transfer

Costa Rica's cross-border virtual-asset transfer rules were put into statute via article 15 quater of Ley 7786, inserted by Ley 10961 and in force since 19 September 2026. The provision requires virtual-asset service providers to obtain and retain FATF-standard originator and beneficiary information for both incoming and outgoing virtual-asset transfers, functionally establishing a travel-rule obligation. It further requires immediate asset-freezing or no-dealing measures with respect to designated persons, aligning the regime with targeted financial sanctions practice, and sets a USD 10,000 transaction-registration threshold. All of this is confirmed, Tier-1-sourced detail drawn directly from the Gaceta publication of the law, making it among the more solidly evidenced elements of Costa Rica's new VASP framework.

This travel-rule obligation should be distinguished from the separate, lower USD 1,000 identification threshold reportedly proposed in CONASSIF's pending implementing-regulation consultation for occasional virtual-asset transactions. The two thresholds are not the same instrument: the USD 10,000 figure is a confirmed statutory transaction-registration threshold already in force, while the USD 1,000 figure is a probable, not-yet-finalised client-identification threshold under consultation. Firms structuring cross-border virtual-asset flows involving Costa Rica should track both figures separately, since the implementing regulation, once finalised, will determine how the statutory travel-rule obligation interacts with lower-value occasional transactions.

#### Outlook

Implementing detail for how the travel-rule obligation will be operationalised in practice, including the originator/beneficiary data-transmission mechanics and the interaction with the proposed USD 1,000 occasional-transaction threshold, is expected via the CONASSIF regulation anticipated in the fourth quarter of 2026 as scheduled. Until that regulation is finalised, the statutory obligation stands confirmed and in force, while its granular implementation remains to be specified.

Periodic update · new data 2026-09-28

#### Cross-Border Transfer

Costa Rica's new AML/CFT obligated-entity status for virtual asset service providers, created under Article 15 quater of Law No. 7786, extends into the cross-border transfer space. Secondary sources report that VASPs will need to apply Travel Rule compliance for cross-border virtual-asset transfers as part of this new obligated-entity status. This is disambiguation context rather than first-party AML analysis: the substantive AML/CFT regime behind the Travel Rule obligation is owned and analysed by the financial_integrity monitor's subscription to this jurisdiction's AML/CFT regime module, and this crypto brief does not re-analyse that substance.

What is relevant from a crypto-specific lens is that cross-border transfer obligations are now formally implicated for Costa Rican VASPs for the first time, tightening the operating environment for firms moving virtual assets across the border, even though the underlying AML/CFT regime analysis sits outside this monitor's scope. Confidence in the precise mechanics of the Travel Rule application remains uncertain, resting on secondary source characterisation rather than a directly retrieved primary regulatory text.

#### Outlook

Watch for primary-source confirmation of the Travel Rule compliance mechanics for VASP cross-border transfers, and for how this interacts with the broader SUGEF registration requirement as its effective date is confirmed.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 8 traced claims · Re-verified 2026-10-25

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### Costa Rica: C9 Commercial Activity unpopulated ▾

## Commercial Activity

One disclosed commercial event touching Costa Rica was identified this cycle: Jeeves, a stablecoin-card platform provider, raised $110 million and expanded its operating footprint from twenty-five to thirty-five countries, naming Costa Rica among the new markets alongside several other Latin American jurisdictions. The event is probable rather than confirmed in its Costa Rica-specific dimension, since no country-specific allocation of the raised capital, nor Costa Rica-specific commercial terms, partnership structure, or operational timeline, were disclosed in the sourced reporting. The announcement is recorded as announced rather than closed or operationally live.

The commercial significance lies less in the transaction's size, which is not meaningfully attributable to Costa Rica specifically, than in its timing relative to the regulatory environment: the expansion proceeds without apparent dependency on, or reference to, Costa Rica's newly in-force VASP AML registration requirement under Ley 10961, or the pending CONASSIF implementing regulation. This suggests that stablecoin-card commercial market entry into Costa Rica is not currently gated by the AML-registration perimeter, consistent with that perimeter functioning as a compliance requirement rather than a market-access licence. — Outlook: No further Costa Rica-specific commercial detail for Jeeves' expansion, including launch timing, transaction volume, or local partnership structure, has surfaced. Should Jeeves or a Costa Rica-specific operating entity subsequently register with SUGEF under the VASP AML regime, that would represent a separate and independently trackable regulatory-compliance development distinct from this commercial announcement.

No periodic updates recorded in this cycle

Sources and findings (1)
- T3[Jeeves](https://fintech.global/2026/10/02/smaller-deals-dominated-this-weeks-fintech-deal-scene-with-541m-raised-across-15-deals/) — Raised $110m and expanded stablecoin-card platform from 25 to 35 countries including Costa Rica; CR-specific allocation not disclosed