Crypto License in Costa Rica

Authorised crypto companies in Costa Rica are entities enrolled on the SUGEF Article 15-bis registry as Virtual Asset Service Providers under Law No. 7786 and SUGEF Agreement 12-21. The registry is publicly accessible and confirms a company’s AML-supervised status, which is the standard banking and payment counterparties verify before onboarding a Costa Rican crypto entity.

Enrollment requires a Costa Rican S.R.L. or S.A. with explicit virtual asset service clauses, a documented AML/CFT program, an appointed compliance liaison, and a Firma Digital-equipped legal representative for portal filings.

Business models covered by the SUGEF VASP framework

• Exchange and brokerage — spot, derivatives, OTC desks, and high-volume liquidity providers.
• Custody and wallet services — hot, cold, and qualified custody, storage and management of client digital assets.
• Crypto payment gateways — crypto-to-fiat and merchant payment processors, B2B settlement rails.
• Staking and yield platforms — centralized or decentralized pool operators.
• DeFi-adjacent platforms — lending, AMMs, yield aggregators with a Costa Rican operating entity.
• Blockchain infrastructure — node operators, validator services, RPC providers, SaaS for Web3.
• Web3 and GameFi projects — token-based ecosystems and play-to-earn models, with a strong synergy for combined crypto-and-gaming structures.
• Tokenization and RWA — utility tokens, GameFi assets, and asset-backed projects.
• Advisory, analytics, and on-chain compliance services — professional services around the crypto stack.

When SUGEVAL jurisdiction applies

Tokens classified as securities — including security-token offerings (STOs) and RWA tokens where the underlying instrument is a security — trigger SUGEVAL (Superintendencia General de Valores) jurisdiction in addition to SUGEF VASP obligations. This dual-supervision scenario applies to ICO/STO structures and to tokenized investment products.

Activities that involve regulated banking, deposit-taking, public investment solicitation, or insurance fall outside the SUGEF VASP framework and require separate financial licensing.

A Costa Rica crypto company must satisfy three layers of requirements: corporate (S.R.L. or S.A. with virtual asset service clauses), AML/CFT compliance (program documentation aligned with FATF VASP Guidance, plus SUGEF Article 15-bis enrollment), and operational readiness (Firma Digital, RTBF beneficial-ownership filing, banking onboarding pack). All three are mandatory, not optional.

Corporate and entity requirements

• Legal vehicle: S.A. or S.R.L. with explicit virtual asset service clauses in the corporate object.
• Registered legal address in Costa Rica. A registered agent address satisfies this requirement — no own office is required.
• Legal representative. At least one named in the corporate registry; in practice, this is the person who will hold the Firma Digital and act on behalf of the company in SUGEF and BCCR portals.
• Tax registration. NITE/RUT issued by the Dirección General de Tributación (DGT) after Registro Nacional incorporation.

AML/CFT program requirements

• Written AML/CFT policy covering risk assessment, transaction monitoring, and customer identification, aligned with FATF VASP Guidance.
• KYC onboarding procedures with identification, verification, ongoing monitoring, and enhanced due diligence for higher-risk clients.
• Compliance officer (Compliance Liaison) appointed to manage SUGEF platform submissions and AML reporting.
• Risk matrix documenting exposure to money laundering and terrorist financing risk by product, geography, and client type.
• Transaction monitoring system with blockchain analytics and AML screening, sized to expected volume.

Beneficial ownership and Firma Digital

• UBO disclosure for any beneficial owner holding 25% or more, under Law 9449 (AML and Transparency Requirements).
• RTBF filing. Beneficial-ownership data submitted through the BCCR Registro de Transparencia y Beneficiarios Finales portal at centraldirecto.fi.cr. Annual renewal by 30 April each year.
• Firma Digital. Required for all SUGEF and BCCR portal filings. Foreign founders satisfy this requirement by appointing a Costa Rican legal representative who holds the credential and signs filings on the company’s behalf.

Documents to prepare

• Passports and proof of address for shareholders, directors, and UBOs.
• Police criminal records, apostilled where required.
• Articles of Incorporation (S.A. or S.R.L.) with VA clauses.
• Tax registration documents (NITE/RUT).
• AML/CFT policy and risk assessment.
• KYC procedures and onboarding rules.
• Compliance officer appointment letter.
• Transaction monitoring description and vendor details.
• Business description and transaction flow overview.

Banking and payment processing readiness

Banks and EMIs typically require completed compliance questionnaires, the AML/KYC manual, the SUGEF registry confirmation, source-of-funds and source-of-wealth declarations, and evidence of an active transaction monitoring system. Properly prepared documentation materially improves approval timelines for banking and payment services.

Crypto in Costa Rica is regulated through three concurrent layers: general commercial law for private contracts, mandatory AML/CFT supervision through SUGEF under Law No. 7786 and SUGEF Agreement 12-21 for VASPs, and CARF tax-transparency reporting under Bill 24.811 for cross-border user data. Cryptocurrencies are treated as private intangible assets, not as legal tender — a position publicly confirmed by the Central Bank of Costa Rica (BCCR).

Legal classification of crypto assets

Cryptocurrencies are classified as private intangible assets under general commercial law. They are not legal tender, and the Colón remains the sole official currency under the Constitution and the Central Bank Act. Private parties may exchange, hold, and transfer crypto under contractual freedom, at their own risk. Tokens classified as securities are pulled into SUGEVAL (Superintendencia General de Valores) jurisdiction in addition to SUGEF VASP supervision.

SUGEF supervision under Article 15-bis

SUGEF (Superintendencia General de Entidades Financieras) supervises VASPs under Article 15-bis of Law No. 7786, with scope formalized by SUGEF Agreement 12-21. Most crypto business models — exchanges, custody, payment gateways, OTC desks, DeFi-adjacent platforms — fall under this regime rather than SUGEVAL. The publicly-accessible registry confirms an entity’s AML-supervised status, which banking and payment counterparties increasingly request as an onboarding condition.

UBO transparency and CARF reporting

Beneficial-ownership transparency operates under Law 9449. Owners holding 25% or more must be disclosed and updated through the BCCR Registro de Transparencia y Beneficiarios Finales (RTBF) portal. CARF — the OECD Crypto-Asset Reporting Framework — has been implemented in Costa Rica through Bill 24.811. VASPs are required to collect and report user transaction data to the Ministerio de Hacienda for automatic exchange with other CARF-participating jurisdictions. Failure creates regulatory exposure both in Costa Rica and in users’ tax-residence countries.

Three shifts define Costa Rica’s 2026 crypto landscape: CARF reporting is now active for VASPs through Bill 24.811, SUGEF Article 15-bis enrollment is treated as a banking precondition by counterparty institutions, and Bill 22.837 remains pending with no licensing regime introduced. The headline change is CARF: 2026 is the first full reporting cycle, not preparation for a future one.

CARF active reporting under Bill 24.811

Costa Rica has implemented the OECD Crypto-Asset Reporting Framework domestically through Bill 24.811. VASPs are required to collect and report user transaction data to the Ministerio de Hacienda for international automatic exchange. Required infrastructure includes user identification fields aligned with CARF schema, transaction record-keeping, and reporting interfaces with the Ministerio de Hacienda system. VASPs serving users in CARF-participating countries face dual exposure if reporting is incomplete — in Costa Rica and in the users’ tax-residence jurisdictions.

SUGEF Article 15-bis registry as banking gate

Banks and payment processors increasingly require the registry confirmation as a precondition for onboarding. Companies operating without enrollment face account refusals and payment disruptions, even when their underlying business is fully compliant in other respects. The registry is no longer optional in practical terms.

Bill 22.837 status

Bill No. 22.837 has passed an initial legislative stage but has not entered into force as of 2026. It does not introduce a discretionary licensing regime; the draft addresses clearer coordination of AML oversight involving SUGEF. The current Article 15-bis framework remains the operative model regardless of the bill’s eventual outcome.

Territorial tax principle (clarified)

The territorial principle (foreign-sourced income generally not taxed) remains in force. With CARF transparency now active, documented economic substance and clear income-sourcing become more important for defending the territorial position. Substance, not the absence of rules, is what now protects the tax outcome.

Successful operation in Costa Rica depends on three things: a properly structured S.R.L. or S.A. with virtual asset clauses, a real AML/CFT program supporting the SUGEF Article 15-bis enrollment, and CARF-aligned data systems. Treating any of the three as optional is the most common avoidable failure mode.

Gofaizen & Sherle covers all three end-to-end. We support crypto and fintech projects at every stage of entry into Costa Rica, including:

• crypto company registration (Costa Rican entity) with virtual asset service clauses and tax setup;
• AML/CFT and KYC framework design;
• SUGEF Article 15-bis enrollment and Compliance Liaison appointment;
• Firma Digital and RTBF filing through a Costa Rican legal representative;
• banking and payment processing onboarding support;
• CARF-aligned data systems and Ministerio de Hacienda reporting infrastructure;
• ongoing regulatory and compliance advisory.

Our role is to ensure that your crypto business in Costa Rica is legally structured, bankable, and CARF-ready — not merely registered.