Cryptocurrency Regulation Gray Zone in Costa Rica: What You Need to Know
Jun, 12 2025
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- Bill 22.837 requires VASPs to register with SUGEF
- Compliance includes KYC, AML policies, and ongoing reporting
- Non-registration can lead to fines and shutdowns
- Costa Rica offers benefits like low taxes and political stability
- Current framework is a "gray zone" with evolving regulations
Cryptocurrency regulation Costa Rica is a rapidly evolving landscape that sits in a legal gray zone. The Central Bank of Costa Rica (BCCR) clarified back in 2017 that Bitcoin and other digital coins aren’t legal tender, yet it didn’t ban private use. That means you can buy, sell, and hold crypto freely, but there’s no specific law spelling out how businesses should operate. The result? A mix of freedom and uncertainty that draws startups like moths to a flame.
How the gray area looks on the ground
In everyday terms, the gray area means you can walk into a café in San José and pay with Bitcoin without the police showing up. At the same time, banks won’t recognize crypto deposits as “official” money, so you can’t expect the same consumer protections you get with a traditional bank account. The BCCR’s 2017 statement is the cornerstone: crypto is not backed by law, not a legal tender, but private transactions are permissible. This creates a “tolerated but not endorsed” environment - a sweet spot for innovators and a potential headache for regulators.
July 2025: The first real legislative push
On July 2, 2025 the Legislative Assembly introduced Bill 22.837, officially titled “Proyecto de Ley Reforma a la Ley sobre Estupefacientes…”. The bill amends Law No. 7786 and adds Article 15 quáter, which drags Virtual Asset Service Providers (VASPs) into the country’s AML/CFT regime. In plain English, any company that exchanges crypto for fiat, holds crypto for clients, or issues tokens now has to register with the financial watchdog.
What counts as a VASP?
The bill defines a "Proveedor de Servicios de Activos Virtuales" (VASP) as anyone who:
- Facilitates exchange between virtual assets and legal tender;
- Transfers virtual assets on behalf of another party;
- Provides custody or administration of virtual assets;
- Issues or markets virtual assets.
Registration with SUGEF: Step‑by‑step
All VASPs must register with the Superintendencia General de Entidades Financieras (SUGEF). Registration is not a license to operate; it’s a compliance checkpoint. Here’s a practical rundown:
- Prepare incorporation documents and secure a legal address in Costa Rica.
- Open a corporate bank account-most local banks require a clear AML policy before onboarding.
- Draft an AML/CFT policy that meets FATF Recommendations (risk assessments, KYC, monitoring).
- Submit the registration form to SUGEF, attaching the AML policy, board details, and a description of services.
- Undergo a risk‑based review; higher‑risk services (e.g., large‑volume exchanges) face deeper scrutiny.
- Once approved, maintain ongoing reporting: transaction logs, client identification, and periodic risk updates.
Failure to register can trigger fines and potential shutdowns, even though the law doesn’t label unregistered activity as illegal outright.
Compliance checklist for crypto businesses
| Requirement | What to Do | Frequency |
|---|---|---|
| Client identification (KYC) | Collect name, ID, address, source of funds | At onboarding and whenever data changes |
| Beneficial owner verification | Identify ultimate owners of corporate clients | At onboarding |
| Transaction monitoring | Flag transactions >USD10,000 or suspicious patterns | Continuous |
| Risk assessment | Evaluate product, client, and geographic risk | Annual review |
| Reporting to SUGEF | Submit suspicious activity reports (SARs) and periodic compliance reports | As required (usually quarterly) |
Why entrepreneurs love Costa Rica’s crypto climate
Besides the regulatory leeway, Costa Rica offers a package of perks that make it a magnet for crypto startups:
- Tax incentives: Low corporate tax rates on foreign‑sourced income, plus exemptions for tech‑related services.
- Political stability: One of the most stable democracies in Central America, reducing geopolitical risk.
- Infrastructure: High‑speed internet, modern data centers, and a growing pool of tech talent.
- Cost‑effective licensing: No minimum share capital, no local director requirement, and the ability to combine a gaming license with a VASP registration.
These factors have turned the country into a hub for GameFi projects, crypto casinos, decentralized exchanges (DEXes), and NFT marketplaces looking for a cheap, fast entry point.
Risks lurking in the gray zone
The upside comes with a set of real risks. First, the lack of explicit legal protection means if a dispute arises, courts may treat crypto assets like any other intangible property-no special safeguards. Second, because the bill’s registration does not equal a government “approval,” authorities could change the rules overnight, leaving businesses scrambling. Third, compliance with international AML standards is still mandatory; any slip‑up can attract hefty fines and damage reputation.
Preparing for future regulation
Smart companies treat the current framework as a stepping stone, not a final destination. Building a robust AML program now pays off if Costa Rica tightens its rules later. Keep an eye on these signals:
- Updates from the Legislative Assembly on Bill 22.837 (especially any amendments to Article 15quáter).
- Guidance from SUGEF on risk thresholds and reporting formats.
- Regional trends - neighboring countries like Panama and Colombia are also shaping crypto policy; shifts there can influence Costa Rica.
By staying proactive, you can preserve the freedom you enjoy today while protecting your business from tomorrow’s restrictions.
TL;DR - Quick takeaways
- Crypto isn’t legal tender in Costa Rica, but private use is allowed.
- Bill 22.837 (July2025) brings VASPs under AML/CFT rules via registration with SUGEF.
- Compliance steps include incorporation, bank account, AML policy, and ongoing reporting.
- Benefits: low tax, stable politics, cheap licensing, strong tech infrastructure.
- Risks: no explicit legal protection, possible regulatory changes, strict AML obligations.
Frequently Asked Questions
Is it illegal to run a crypto exchange in Costa Rica?
No. The law doesn’t forbid exchanges, but they must register with SUGEF and follow AML/CFT rules. Failure to register can lead to sanctions.
Do I need a special crypto license to operate in Costa Rica?
There’s no dedicated crypto license. You register as a VASP with SUGEF and comply with the AML framework. Some businesses also obtain a gaming license to combine services.
What are the tax implications for foreign crypto companies?
Foreign‑sourced income is generally taxed at a low rate, and many crypto‑related services qualify for tax incentives. However, you must file annually and keep detailed records.
How does the AML compliance differ from traditional finance?
The core principles are the same-KYC, transaction monitoring, reporting-but you’ll need to flag crypto‑specific red flags like rapid wallet hopping, mixing services, and high‑volume token swaps.
Can I use a local bank for crypto transactions?
Most banks are cautious, but if you have a solid AML policy and transparent transaction records, several banks will open corporate accounts for crypto‑related businesses.
WILMAR MURIEL
June 12, 2025 AT 18:24Reading through the Costa Rican crypto regulation landscape really makes me think about how fragile the balance between innovation and oversight can be. It’s clear that the country is trying to walk a tightrope, offering enough freedom to attract startups while still keeping an eye on money‑laundering risks. The 2017 BCCR statement set a precedent, but without explicit rules businesses were left navigating a foggy gray zone. This uncertainty can be stressful for founders, especially when they have to prove that they’re compliant without a clear playbook. I’ve seen similar scenarios in other emerging markets, where the lack of definitive guidance forces companies to over‑invest in legal counsel just to stay safe. That over‑investment can divert resources away from product development, slowing down the entire ecosystem. On the other hand, the introduction of Bill 22.837 in July 2025 is a promising step toward clarity, even if it feels a bit heavy‑handed at first.
What really matters now is how the registration process with SUGEF plays out. If the authorities can make the process transparent, affordable, and predictable, many entrepreneurs will feel more secure. The requirement to have a solid AML/CFT policy aligned with FATF standards is reasonable, but the devil is in the details – especially for startups that may not have the bandwidth to build such robust systems from day one.
For those considering Costa Rica, the tax advantages and stable political environment are genuine incentives. Low corporate tax rates on foreign‑sourced income can dramatically improve the bottom line, and the modern tech infrastructure means you won’t be fighting for bandwidth. Yet, the lack of explicit legal protection for crypto assets in dispute scenarios remains a red flag. If a conflict arises, courts may treat those assets like any other intangible property, which could leave investors vulnerable.
It’s also worth noting the cultural aspect: Costa Rican regulators seem to prefer a “watch‑and‑wait” approach. This can be both a blessing and a curse. While you get the freedom to experiment, you also sit on the edge of potential sudden regulatory shifts. That’s why I always advise founders to build adaptable compliance frameworks now, rather than waiting for a crackdown later.
In summary, the region offers a fertile ground for crypto ventures, but the path is strewn with both opportunities and hidden pitfalls. Proceed with optimism, but keep a vigilant eye on regulatory updates, and consider partnering with local legal experts who understand the nuances of SUGEF’s expectations.
carol williams
June 22, 2025 AT 07:12While I appreciate the optimism, let’s not gloss over the fact that Bill 22.837 essentially forces every crypto business into a bureaucratic maze. The registration with SUGEF isn’t just a formality; it’s a gatekeeper that can stall operations for months. Moreover, the AML requirements are not merely suggestions – they’re enforceable standards that, if ignored, lead to heavy fines. So, if you think you can sidestep the process because “crypto is new,” think again. The legislative intent is crystal clear: bring VASPs under the same scrutiny as traditional financial institutions.
Maggie Ruland
July 1, 2025 AT 20:00Great stuff, but I’m still waiting for the day when I can buy a coffee with Bitcoin in San José without looking over my shoulder.
jit salcedo
July 11, 2025 AT 08:48Honestly, the whole thing feels like a staged performance – the government throws a few regulatory breadcrumbs and then watches the crypto crowd scramble like rats in a maze. It’s almost as if there’s an invisible hand guiding the narrative, perhaps to keep the sector under the radar while pretending to be progressive. The “gray zone” is just a euphemism for controlled chaos, designed to keep small players off‑balance and large, well‑connected entities thriving.
Joyce Welu Johnson
July 20, 2025 AT 21:36If you’re looking to set up a VASP in Costa Rica, the first step is to make sure your company is properly incorporated with a legal address. After that, you’ll need to open a corporate bank account – many local banks will ask for a detailed AML policy before they even consider you. Draft your AML/CFT policy to match FATF guidelines: include KYC procedures, risk assessments, and transaction monitoring thresholds (usually $10,000). Once those documents are ready, submit the registration form to SUGEF with all supporting materials. After approval, remember you have ongoing reporting obligations, such as quarterly SARs and annual compliance reviews. Skipping any of these steps can result in fines or even forced shutdowns.
Ally Woods
July 30, 2025 AT 10:24Sounds like a lot of paperwork, but honestly, if you’ve already got a solid compliance stack, it’s not that bad.
Kristen Rws
August 8, 2025 AT 23:12Whoa, this is amazing! Costa Rica is like a hidden gem for crypto start‑ups. Cant wait to see it boom!
Fionnbharr Davies
August 18, 2025 AT 12:00The enthusiasm is great, but let’s also keep a realistic view. Sustainable growth comes from building solid foundations – legal, technical, and community. If you pair the tax incentives with a robust compliance program, you’ll create a resilient ecosystem that can weather future regulatory shifts.
Narender Kumar
August 28, 2025 AT 00:48To Whom It May Concern, the current legislative framework, while commendable in its intent, imposes a considerable administrative burden upon nascent VASPs. It is incumbent upon these entities to meticulously adhere to the stipulated AML and CFT protocols, lest they incur punitive measures of a severe nature. In the interest of safeguarding both investor confidence and national financial stability, prompt compliance is not merely advisable but imperative.
Lisa Strauss
September 6, 2025 AT 13:36Exactly! Let’s look on the bright side – those challenges are just stepping stones toward a stronger, more trustworthy crypto community in Costa Rica. Keep pushing forward!
Darrin Budzak
September 16, 2025 AT 02:24It’s cool to see the excitement, but remember that regulatory clarity is a two‑way street. Regulators need transparency from businesses just as much as businesses need clear rules. A collaborative approach will benefit everyone.
Andrew McDonald
September 25, 2025 AT 15:12Honestly, the “collaborative approach” sounds like a buzzword to me. If you’re not already compliant, you’ll just be dancing around the inevitable crackdown. 🙂
Megan King
October 5, 2025 AT 04:00yeah, but the regs are real and it dont matter what u think. you gotta get that SUGEF registration or u can be in trouble. the key is to start early and get legal help if u can.