Virtual asset service providers in Costa Rica must prepare to register with financial regulator SUGEF under a new anti-money laundering framework that is due to take effect in September 2026. Once the relevant requirements apply, providers operating without the required registration could face regulatory penalties and restrictions on their relationships with SUGEF-supervised financial institutions.
The changes stem from Ley 10961, signed into law in June 2026. The legislation amends Costa Rica’s 1998 anti-money laundering framework and brings virtual asset service providers under formal supervision. Its scope includes businesses that exchange crypto assets for fiat currency, transfer digital assets on behalf of clients, provide custody services, or participate in the issuance or sale of virtual assets. Exchanges, custodians, payment processors and OTC desks may therefore fall within its scope depending on their activities.
In-scope providers will be subject to anti-money laundering and counter-terrorist financing obligations. These include identifying customers and beneficial owners, maintaining transaction records, applying enhanced due diligence in higher-risk situations and conducting relevant sanctions screening.
The framework also establishes reporting and compliance obligations for covered providers. Where applicable, businesses may be required to freeze assets linked to sanctions designations and report relevant cases to the Financial Intelligence Unit at Costa Rica’s Instituto Costarricense sobre Drogas. Suspicious transactions must also be reported in accordance with the applicable AML requirements.
The consequences of non-compliance extend beyond registration itself. SUGEF-supervised financial institutions will face restrictions on maintaining commercial relationships with virtual asset service providers that have not fulfilled the applicable registration requirements. The legislation also provides for financial penalties for certain violations, making registration and ongoing AML compliance operational issues rather than a one-time filing exercise.
“Most founders read this as a paperwork exercise. It isn’t,” said Aaron Glauberman, Co-Founder and Managing Partner at LegalBison. “Once the ban on servicing unregistered providers takes hold, a company without a SUGEF filing loses its ability to operate as a service provider in Costa Rica.”
That assessment comes from LegalBison, a corporate services firm that advises businesses on regulatory registration and therefore has a commercial interest in the compliance services discussed in this article.
Companies within the scope of the new framework will also need an appropriate compliance function based on their activities, risk profile and scale. Depending on the company’s structure and applicable requirements, this may involve appointing a compliance officer or establishing an equivalent compliance structure.
LegalBison provides commercial assistance with regulatory registration and compliance implementation. Its services include corporate structuring and crypto license in Costa Rica advisory work for businesses assessing how the country’s new regulatory framework applies to their operations.
For crypto businesses operating in or entering Costa Rica, the practical priority is to determine whether their activities fall within the law’s scope and, if so, identify the registration and compliance requirements that apply before the new framework becomes effective.
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