🇨🇷 COSTA RICA - VASP REGULATORY CHANGES
Costa Rica's Legislative Assembly unanimously passed Legislative Decree No. 10961, amending Law No. 7786 (the AML/CFT Law) to incorporate Virtual Asset Service Providers as obligated subjects for the first time.
📋 WHAT CHANGED:
VASPs must now register with SUGEF (Superintendencia General de Entidades Financieras) for AML/CFT supervision. The law introduces formal legal definitions of "virtual asset" and "VASP" covering exchange, transfer, custody, financial services related to issuance, offering, and commercialization of virtual assets.
⚠️ CRITICAL DISTINCTION:
Registration ≠ Operating license. The law is explicit — SUGEF registration does not constitute an authorization or permit to operate. Costa Rica still has no formal VASP operating license.
BUT — financial institutions are now restricted from serving VASPs that fail to register when required. In practice, registration is becoming a banking access gatekeeper.
📌 MANDATORY AML/CFT OBLIGATIONS NOW IN FORCE:
- Customer identification and beneficial owner verification (KYC/CDD)
- Transaction records maintained and available on request
- Enhanced controls for Politically Exposed Persons (PEPs)
- Risk assessment for new products, services, and technologies
- Controls over virtual asset transfers (Travel Rule)
- Suspicious transaction reporting to the FIU (UIF) of the ICD
💰 PENALTIES for non-compliance: USD $1,800–$90,000 per violation or 5–50% of the transaction value.
⏳ STATUS: Passed — awaiting presidential signature. After publication in La Gaceta, CONASSIF has 3 months to issue implementing regulations defining thresholds, supervision criteria, and practical obligations.
🔑 BOTTOM LINE:
Costa Rica remains a jurisdiction without a formal VASP license. But the grace period is ending. Build your AML/CFT framework now — when CONASSIF regulations arrive, compliant operators will be ready. Non-compliant operators risk losing banking access.
Zitadelle AG assists with Costa Rica company formation, SUGEF registration preparation, AML/CFT compliance frameworks, banking introductions, and legal opinions for VASP operators.
🔗 Full guide: https://www.zitadelleag.com/services/vasp-licensing/costa-rica-panama-vasp
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Costa Rica Company Setup 2026 — Crypto, iGaming & VASP
Set up a Costa Rica company for crypto, iGaming, or VASP — 0% foreign income tax, 1–2 week incorporation, SUGEF registration, banking & legal opinion. Zitadelle AG.
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