How to Open a Bank or EMI Account for a Costa Rica VASP

Last updated: 9 September 2026

Opening a bank or EMI account for a Costa Rica VASP is a provider-fit and evidence exercise, not an automatic result of incorporation or SUGEF registration. Define the bank account’s purpose and map every fiat and crypto flow. Pre-screen providers, then submit one provider-ready file covering the company, owners, business, transactions, financial capacity and controls. Preparation may reduce rework, but the provider still decides whether to accept the customer, offer the requested product and keep the account open in normal day-to-day use.

Status of Law 10961 for banking. Law 10961 was published on 19 June 2026 and is due to bring in-scope VASPs into Costa Rica’s AML/CFT supervision on 19 September 2026. The official text says SUGEF registration is not operating authorization. Once effective, it will prohibit Article 14 entities and subjects registered under Articles 15, 15 bis, 15 ter and 15 quater from doing business with persons performing Article 15 quater activities without due registration. This neither compels onboarding nor binds every foreign EMI. A bank account is not guaranteed. When checked on 9 September 2026, SUGEF’s public consultation page did not list a VASP-specific proposal. Recheck the rules, filing process and status. See crypto regulation in Costa Rica after Law 10961.

Bank or EMI: Quick Decision

Choose by use case, not label. Confirm that the provider’s legal entity and product support the applicant and flow.

An EMI is not a bank. Under the EU E-Money Directive, e-money funds are not deposits and must be safeguarded. The UK FCA explains the UK position. Insolvency outcomes vary by jurisdiction and structure. Check an EU candidate in the EBA register and its home register.

1. Map the Funds Flow

Define the applicant and bank account purpose. Show payer, payee, asset or currency, account or wallet, jurisdiction, counterparty type, frequency, normal and peak amounts, refunds and chargebacks. Include crypto conversion, third-party payments and customer-money legs. Produce a one-page map and expected-activity table separating expenses, treasury, settlement, acquiring and client funds.

2. Pre-Screen Providers

Do not use an evergreen “crypto-friendly banks” list. For each candidate, record its legal entity, register link and date, Costa Rica company/activity/country fit, product, rails, currencies, limits, client-money position, open points, decision and evidence owner. Confirm fees and terms directly. Treat written pre-screening as preliminary.

3. Prepare Corporate and UBO Evidence

Create one KYB set covering legal existence, constitutional documents, ownership to natural-person UBOs, directors, signatories, authority, addresses, substance, tax IDs and financials. Follow the provider’s current formalities.

A startup may use founder-funding evidence, contracts and grounded projections. Mature companies may need accounts and intercompany agreements. Names, percentages, addresses and signing powers must reconcile.

Gofaizen & Sherle can assess entity fit and evidence gaps through its Costa Rica VASP setup and banking-readiness support.

4. Explain the Business and Transactions

Describe services, customers, markets, revenue, account purpose, transactions and financial capacity. Support them with the website, terms, contracts and exact scope of any registration or license. The website, flow map and application must agree. Do not equate registration with licensing, call an AML-registered applicant a “licensed VASP” or hide higher-risk features.

5. Show AML/KYC and Crypto Controls

Providers need operating evidence, not only an AML policy.

See Costa Rica VASP AML/KYC requirements after registration.

6. Evidence Funds, Wealth and Counterparties

Source of funds connects company funding or a transaction to subscriptions, loans, contracts, invoices or statements. Source of wealth shows how a UBO accumulated assets through employment, business, sale, dividends or investments. Link counterparties and purposes to the flow map. Minimise and secure personal data.

7. Apply and Answer Due Diligence

Appoint one owner. Keep a secure data room, fact sheet and query log covering each question, source, response and open point. Answer enhanced due diligence (EDD) questions on crypto exposure, countries, counterparties, volumes, wallets, client funds and funding from the same evidence. Escalate gaps and review conditions before accepting an offer.

8. Fix Common Blockers

If Costa Rica coverage or local functionality makes the route impractical, compare Costa Rica and Panama for a crypto company. Another jurisdiction may alter the options, not guarantee banking.

9. Keep the Account Operational

Use a maintenance calendar:

Maintain a proportionate contingency route, but never evade monitoring or use personal or unrelated accounts.

Banking-Readiness Checklist

Before submission, confirm these 12 items:

1. Account use and owner are defined.
2. Fiat and crypto flows are mapped end to end.
3. Countries, currencies, counterparties and volumes are documented.
4. Provider authorization, coverage and activity fit are checked.
5. Corporate, UBO and signatory records reconcile.
6. Website, contracts and application agree.
7. Financial history or projections are supported.
8. Source of funds and source of wealth are separated.
9. Client money, safeguarding, acquiring and third-party payments are identified.
10. AML/KYC controls have owners and operating evidence.
11. Regulatory status is described precisely in one fact set.
12. Post-opening monitoring has an owner.