Costa Rica Crypto Regulation Checker
Current Legal Status
Cryptocurrencies are not legal tender but are not banned either. Private individuals can trade freely, but businesses require VASP registration.
Gray ZoneNew Regulatory Framework
Bill 22.837 introduces VASP definitions and registration requirements with SUGEF, but no formal licensing yet.
Emerging FrameworkCheck Your Compliance Status
Compliance Summary
Key Regulatory Changes (Before vs After)
| Aspect | Before July 2025 | After Bill 22.837 |
|---|---|---|
| Legal status of crypto | Not legal tender; no specific law | Defined as "Activo Virtual"; still not legal tender |
| VASP requirement | None; businesses relied on general financial law | Mandatory registration with SUGEF |
| AML/CFT obligations | General AML law, but no crypto-specific guidance | Risk-based AML/CFT compliance explicitly required |
| Capital requirements | None for crypto firms | Still none; legislation leaves capital-minimum out |
| Tax treatment | Standard corporate tax (15%) | Unchanged; but potential future crypto-specific incentives |
When you hear "cryptocurrency regulation in Costa Rica", youâre probably picturing a clear set of rules. In reality, the landscape sits in a legal gray zone: not outright banned, but also not fully defined. This article untangles the current framework, breaks down the July 2025 bill that tries to bring virtualâasset service providers (VASPs) under antiâmoneyâlaundering supervision, and shows you how to operate safely while the rules keep evolving.
Current Legal Status: No Law, Some Guidance
Cryptocurrency regulation in Costa Rica is currently defined by a vacuum rather than a concrete statute. The Central Bank of Costa Rica (BCCR) clarified in October 2017 that Bitcoin and other digital tokens are not legal tender and have no backing from any law. Yet, private parties may still trade crypto assets freely. This creates a dual reality: individuals can buy, sell and hold coins, but businesses lack a specific licence to offer cryptoârelated services.
The July 2025 Bill 22.837: First Steps Toward Structure
On 2July2025, the Legislative Assembly debated Bill22.837, officially titled âProyecto de Ley Reforma a la Ley sobre EstupefacientesâŚâ. The bill amends LawNo.7786 by adding Article15quĂĄter, which formally defines âActivo Virtualâ (Virtual Asset) and âProveedor de Servicios de Activos Virtualesâ (VASP). The definition reads: any digital representation of value that can be transferred online, but not recognized as legal tender.
Superintendencia General de Entidades Financieras (SUGEF) is tasked with supervising VASPs. Registration with SUGEF does not grant a government âauthorizationâ to operate; it simply confirms that the entity complies with the countryâs AML/CFT regime.
What Registration with SUGEF Actually Means
- Identify clients and ultimate beneficiaries.
- Retain detailed transaction logs for at least five years.
- Apply enhanced dueâdiligence for politically exposed persons (PEPs) and highârisk jurisdictions, following FATF recommendations.
- Perform regular risk assessments and keep internal controls upâtoâdate.
- Share suspiciousâactivity reports with the authorities through a secure channel.
These requirements mirror the global AML/CFT standards but stop short of granting a formal operating licence. The riskâbased approach means that SUGEF will focus its inspections on entities handling large volumes or dealing with highârisk customers.
Practical Steps for Crypto Startâups
- Incorporate a legal entity via the National Registry. The process takes 3-5 business days and requires a local legal address.
- Open a corporate bank account. While Costa Ricaâs banks remain cautious, many fintechâfriendly institutions now accept cryptoârelated businesses, especially if AML policies are robust.
- Draft an AML/CFT policy that covers KYC, transaction monitoring, and reporting. Use the FATFâs 40âpoint recommendation list as a checklist.
- Register with SUGEF as a VASP. Submit identification documents, a description of services, and your AML program. Expect a review period of 30â45 days.
- Implement ongoing compliance: quarterly risk reviews, staff training, and regular updates to your KYC database.
Failure to meet these steps can lead to fines, asset freezes, or even criminal investigation under Costa Ricaâs moneyâlaundering statutes.
Why Crypto Companies Love Costa Rica
The country offers a blend of lowâcost incorporation, minimal capitalâraising requirements, and a stable political environment. For GameFi projects, the local gaming licence can be combined with a VASP registration, allowing rapid market entry without needing a physical office or resident directors. Telecom infrastructure ranks among the best in Central America, ensuring reliable node connectivity for decentralized applications.
Tax incentives also play a role: foreignâsource income earned by a Costa Rican entity is generally taxed at a modest 15% corporate rate, with many cryptoârelated profits qualifying as capital gains and thus benefiting from favorable treatment.
The Dark Side: Risks and Uncertainties
Operating in a gray zone means you lack explicit legal protection. If a dispute arises over a smartâcontract failure, Costa Rican courts may treat the transaction as a private contract without any statutory safeguards. Moreover, the pending legislation explicitly states that registration is not a licence, leaving businesses vulnerable to future regulatory shifts.
International partners may also hesitate. A U.S. bank, for instance, could deem a Costa Rican VASP âhighâriskâ, limiting correspondentâbank relationships. To mitigate, firms should adopt a proactive compliance posture-maintaining auditâready documentation and staying ready for tighter rules.
Future Outlook: From Gray to Clear?
Experts anticipate that Bill22.837 will be the seed for a more comprehensive crypto code. Possible future steps include:
- Introducing a dedicated crypto licence that separates VASP duties from traditional financial services.
- Setting minimum shareâcapital thresholds to ensure financial resilience.
- Creating a cryptoâspecific tax regime, potentially offering exemptions for blockchainâbased R&D.
Until then, the prudent approach is to treat Costa Rica as a âsandboxâ - capitalise on the low entry barriers while building compliance systems that can be ported to stricter jurisdictions.
Regulatory Snapshot: Before vs. After Bill22.837
| Aspect | Before July2025 | After Bill22.837 |
|---|---|---|
| Legal status of crypto | Not legal tender; no specific law. | Defined as âActivo Virtualâ; still not legal tender. |
| VASP requirement | None; businesses relied on general financial law. | Mandatory registration with SUGEF. |
| AML/CFT obligations | General AML law, but no cryptoâspecific guidance. | Riskâbased AML/CFT compliance explicitly required for VASPs. |
| Capital requirements | None for crypto firms. | Still none; legislation leaves capitalâminimum out. |
| Tax treatment | Standard corporate tax (15%). | Unchanged; but potential future cryptoâspecific incentives. |
Frequently Asked Questions
Is cryptocurrency legal in Costa Rica?
Yes, private individuals can buy, sell, and hold crypto. However, it is not legal tender and there is no specific regulatory framework for businesses, placing activities in a gray area.
Do I need a licence to run a crypto exchange in Costa Rica?
You must register as a VASP with SUGEF and comply with AML/CFT rules, but registration is not a formal licence. No capitalâdeposit or localâdirector requirements exist yet.
What AML measures are required for VASPs?
Identify clients and beneficiaries, keep transaction records for five years, perform enhanced due diligence on PEPs, conduct periodic risk assessments, and file suspiciousâactivity reports to the authorities.
Can I combine a gaming licence with a VASP registration?
Yes, many cryptoâgaming projects use Costa Ricaâs gaming licence alongside VASP registration, allowing fast market entry without a physical office.
What are the tax implications for crypto profits?
Corporate profits are taxed at 15%. Capital gains from crypto may be treated as ordinary income, but many firms benefit from foreignâsource exemptions and can plan for lower effective rates.
Dyeshanae Navarro
August 1, 2025 AT 13:46Embracing Costa Rica's nascent crypto framework can spark innovative financial pathways for many.
Matt Potter
August 13, 2025 AT 21:09The new VASP registration is a golden opportunity, dive in now and lead the market!
Marli Ramos
August 26, 2025 AT 04:32lol đ this whole gray zone thing feels like a neverâending tutorial lol
Christina Lombardi-Somaschini
September 7, 2025 AT 11:55It is essential, therefore, for emerging crypto enterprises to recognize that the mandatory registration with SUGEF does not constitute a traditional operating licence; consequently, firms must implement robust AML/CFT frameworks, maintain meticulous transaction logs for a minimum of five years, and conduct periodic risk assessments, all in strict accordance with FATF recommendations; moreover, the absence of capitalâminimum requirements should not be misconstrued as regulatory leniency, for the supervisory authority retains the discretion to impose corrective measures should compliance deficiencies arise.
katie sears
September 19, 2025 AT 19:18While the optimism expressed above is commendable, it is prudent to balance enthusiasm with due diligence; prospective VASPs should first audit their internal KYC procedures, verify that their transactionâmonitoring tools meet SUGEFâs specifications, and then, if satisfied, proceed with registration, thereby ensuring a sustainable operational foundation.
Gaurav Joshi
October 2, 2025 AT 02:41One must understand that ignoring the moral responsibility of preventing illicit finance is unacceptable; the law may appear ambiguous but it demands ethical conduct from every participant.
Kathryn Moore
October 14, 2025 AT 10:04Registration with SUGEF simply means you must keep records and report suspicious activity; it does not grant you a special privilege.
Christine Wray
October 26, 2025 AT 16:27Balancing the opportunities and risks is key; the sandboxâlike environment can foster growth, yet firms should stay adaptable to future regulatory refinements.
roshan nair
November 7, 2025 AT 23:50First, incorporate a legal entity with a local address; second, open a corporate bank account that accepts cryptoârelated activity; third, draft a comprehensive AML/CFT policy referencing the FATF 40âpoint checklist; fourth, submit the registration dossier to SUGEF and anticipate a 30â45 day review; finally, implement continuous monitoring and quarterly risk reviews to stay auditâready for any regulatory updates.
Jay K
November 20, 2025 AT 07:14In accordance with the prevailing statutes, it is advisable for entities to establish internal controls that satisfy the supervisory expectations of SUGEF, thereby mitigating potential enforcement actions.
Kimberly M
December 2, 2025 AT 14:37Keep calm and comply â the process may seem daunting, but a systematic approach will ease the journey đ
Navneet kaur
December 14, 2025 AT 22:00this system is confusing and i think its not fair for startups
Marketta Hawkins
December 27, 2025 AT 05:23Sure, because every crypto project loves vague regulations đ
Drizzy Drake
January 8, 2026 AT 12:46Alright, let me break this down for anyone whoâs still trying to wrap their head around Costa Ricaâs crypto scene â first off, the country isnât treating Bitcoin like official money, so you wonât see it on any government ledger; however, youâre absolutely free to buy, sell, or hold it as an individual, which is a relief for many traders who were worried about outright bans. When it comes to running a business, the new Bill 22.837 changes the game by defining âActivo Virtualâ and forcing any service provider to register as a VASP with SUGEF â think of it as a checkpoint rather than a fullâblown licence, but you still have to prove youâre not a moneyâlaundering conduit. That means solid KYC procedures, a fiveâyear transaction archive, and regular risk assessments, all of which echo the global FATF standards weâve all grown accustomed to. On the practical side, youâll need a local legal entity, which is surprisingly quick to set up, and a corporate bank account â some banks are cautious, but a few fintechâfriendly ones are already on board. Once youâve got the paperwork sorted, you file the registration, wait about a month, and if everything looks clean, you get the green light to operate. Tax-wise, profits are taxed at the standard 15âŻ% corporate rate, and thereâs potential for cryptoâspecific incentives down the line, so keep an eye on any legislative updates. The upside is huge: low incorporation costs, decent infrastructure, and a stable political climate that makes it attractive for GameFi projects that can even pair a gaming licence with a VASP registration, bypassing the need for a physical office. Of course, there are downsides â the lack of explicit legal protection means disputes might end up as private contracts with limited recourse, and international partners may label you as highârisk, affecting banking relationships. Bottom line: treat Costa Rica as a sandbox, build robust compliance now, and youâll be ready to pivot if tighter rules arrive.