RESEARCH: Costa Rica Cryptocurrency and Digital Asset Securities Regulatory Requirements

Executive Summary

In Costa Rica, the regulatory landscape for cryptocurrencies and digital assets is evolving but remains largely permissive as of 2025–2026. The primary regulator is the Superintendencia de los Sistemas de Pago (SUGEF), which oversees virtual asset service providers (VASPs) under Law 7786 and the subsequent amendments through Law 10961. However, Costa Rica does not currently mandate a formal VASP operating license, and the registration requirement is optional, focusing more on AML/CFT compliance and beneficial ownership disclosures. As of June 2026, no formal VASP licenses have been issued, and the practical reality allows crypto businesses to operate with minimal regulatory hurdles, provided they adhere to AML/CFT and RTBF (Registro de Títulos y Beneficiarios Financieros) requirements. The legal framework is still catching up with global standards, particularly concerning securities aspects, leaving significant gaps and risks for market participants.

Regulatory Framework

• 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 of 2019 established the baseline AML/CFT framework for virtual asset businesses. Costa Rica Crypto AML/CFT & RTBF Requirements 2026
• 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 the Financial Action Task Force (FATF), aligning its AML/CFT standards with international best practices. Costa Rica Crypto Regulation 2026: Law 10961 VASP

Licensing Requirements

• 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
• Structural Requirements: Entities must be legally registered in Costa Rica and maintain operational infrastructure compliant with SUGEF guidelines. No formal license has been issued as of June 2026, indicating a de facto registration-based approach. Costa Rica & Panama Crypto Company 2026

AML/KYC Requirements

• Customer Due Diligence (CDD): VASPs must verify the identity of customers through Know Your Customer (KYC) procedures, including identification documents and source-of-funds verification. Costa Rica Crypto Regulation 2026: Law 10961 VASP
• Enhanced Due Diligence (EDD): Required for higher-risk clients, such as politically exposed persons (PEPs) or those from high-risk jurisdictions. Costa Rica Crypto AML/CFT & RTBF Requirements 2026
• Suspicious Transaction Reporting (STR): VASPs must report any suspicious transactions to SUGEF within 5 days of detection. Costa Rica Crypto AML/CFT & RTBF Requirements 2026
• Beneficial Ownership Disclosure: Mandatory filing of beneficial ownership information through the RTBF, aligning with FATF recommendations. Costa Rica Crypto AML/CFT & RTBF Requirements 2026

Enforcement Actions

• As of June 2026, no specific enforcement actions against crypto businesses have been publicly reported in Costa Rica. The regulatory environment remains largely untested in terms of penalties or arrests, reflecting a cautious rollout of compliance requirements. Costa Rica & Panama Crypto Company 2026

Tax Treatment

• Tax on Crypto Gains: Costa Rica does not provide explicit tax guidance for virtual assets. Income from crypto transactions is generally taxed as income from other sources, but specific rates and thresholds are not defined. Regulations & Tax 2026 - Costa Rica Crypto Licenses
• Capital Gains Tax: Absence of clear capital gains tax rules for virtual assets leaves room for interpretation, potentially subjecting gains to regular income tax rates. Regulations & Tax 2026 - Costa Rica Crypto Licenses

Key Gaps & Risks

• Regulatory Gaps: The lack of a formal VASP license and the absence of explicit capital thresholds create uncertainty for market participants. The focus on registration rather than licensing may lead to inconsistent compliance enforcement.
• Tax Uncertainty: Without specific tax guidance, businesses face ambiguity regarding the tax treatment of crypto income and gains, potentially leading to non-compliance risks.
• International Alignment: While aligned with FATF standards, the implementation lag in Costa Rica may result in delayed compliance with evolving global AML/CFT expectations.
• Operational Risks: The reliance on self-regulation and minimal penalties for non-compliance poses operational risks, particularly for new entrants and larger-scale operations.

Sources

• Costa Rica introduces a VASP framework
• Costa Rica Crypto Regulation 2026: Law 10961 VASP
• Costa Rica Crypto AML/CFT & RTBF Requirements 2026
• Costa Rica Cryptocurrency Regulations: Requirements for ...
• Costa Rica & Panama Crypto Company 2026
• Regulations & Tax 2026 - Costa Rica Crypto Licenses
• Costa Rica Crypto License 2026: SUGEF Rules Explained
• Crypto License in Costa Rica
• Proposed Rule: Regulation Crypto Assets
• Costa Rica Crypto Regulation 2026: Law 10961 VASP