COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Gregory Lutsenko
03.08.2025 | 6 min read
Updated: 20.10.2026
Registering a cryptocurrency company in Costa Rica still opens the way to Latin American markets, but the rules have changed. Since 19 September 2026, virtual asset service providers must register with SUGEF and meet AML/CFT requirements. Let us look at what this means for your project and how this regime differs from MiCA.
What Has Changed: Law No. 10961
Law No. 10961 was published on 19 June 2026 in Supplement (Alcance) No. 78 to the official gazette La Gaceta No. 113. It entered into force three months after publication, that is, on 19 September 2026. The law added Article 15 quater to Law No. 7786, which governs the prevention of money laundering and terrorist financing. Virtual asset service providers (VASPs) are supervised by the General Superintendency of Financial Entities (SUGEF).
COREDO practice shows: a crypto business structure in Costa Rica should be built from the start with FATF standards and AML compliance requirements in mind. That way, documents do not have to be redone for SUGEF registration and the bank's review.
Who Must Register with SUGEF
The law treats as a VASP any natural or legal person who, as a business, provides services with virtual assets for itself or for third parties. This covers exchange between virtual assets and legal tender or between different virtual assets. It also covers transfers, as well as custody, administration or control of virtual assets. Participation in the issuance, marketing, offering or sale of virtual assets is covered too. A virtual asset is not recognised as legal tender in the country.
(before Law No. 10961 entered into force) The COREDO team has implemented cases where setting up a cryptocurrency company in Costa Rica allowed a client to start legal operations within 3-4 weeks while fully complying with KYC requirements and investor rights protection. This approach is especially effective for projects dealing with asset tokenization, stablecoins, and VASP (Virtual Asset Service Providers).
Buying a Cryptocurrency Company in Costa Rica
A ready-made cryptocurrency company in Costa Rica speeds up the corporate part of the launch, but it does not replace SUGEF registration. SUGEF checks the participants, associates and beneficial owners of a VASP for links to offences under Law No. 7786. That is why due diligence remains the key stage: the company's legal integrity, its transaction history and the absence of restrictions from regulators.
Our experience at COREDO has shown that buying a ready-made company with a transparent history and properly prepared corporate documents reduces risks for investors. After a change of owners, the SUGEF registration data must be updated: the law requires it to be kept current.
Registering a Crypto Company in Costa Rica
Registering a crypto company in Costa Rica now has two parts: setting up the company and registering as a VASP with SUGEF. Without the second part, you cannot provide virtual asset services in the country. The key steps are set out below.
Registration and Licensing: Stages
Law No. 10961 does not introduce licences in the usual sense: registration with SUGEF is mandatory, and it is not an authorisation to operate. The process includes several stages:
- Choosing the company form and name.
- Preparing the articles of association with the specifics of crypto activity in mind.
- Appointing a director and disclosing shareholders and beneficial owners.
- Mandatory registration as a virtual asset service provider (VASP) with SUGEF.
- Opening a corporate account for the crypto company.
- Implementing an AML/CFT policy, risk assessment and KYC procedures.
The COREDO team helps you go through these stages in order: from choosing the company structure to preparing the information for SUGEF registration.
Documents for Registering a Crypto Business
The list of information required for VASP registration is set by the regulator. A company's basic package usually includes:
- Articles of association with a description of the activity.
- Identity documents of shareholders, directors and beneficial owners.
- Proof of address.
- A description of the business model, the virtual asset services and the sources of funding.
- A written AML/CFT risk assessment and internal KYC/AML procedures.
COREDO's practice shows: thorough preparation of documents and preliminary due diligence make registration much easier and reduce the risk of refusal by banks.
Corporate Account for a Crypto Business in Costa Rica
Banks and other obliged entities under Law No. 7786 may not maintain business relationships with a VASP that is not registered with SUGEF. Registration therefore becomes a condition for opening a corporate account in the country. Banks also check the transparency of transactions, the origin of funds and the AML policy.
The COREDO team supports clients at every stage of integration with payment systems, ensuring compliance with due diligence and client data protection requirements.
AML and KYC for Crypto Companies in Costa Rica
AML and KYC for crypto companies in Costa Rica have been a legal obligation since 19 September 2026, not a voluntary standard. SUGEF supervises on a risk basis and takes into account the company's size, structure and volume of transactions.
Implementing International Standards: Requirements
Article 15 quater lists the obligations of a VASP. These are identification of clients and beneficial owners, due diligence based on independent sources, and keeping records of transactions. They also include controls on politically exposed persons, on the risks of new technologies and on virtual asset transfers. Enhanced measures are required for higher-risk countries. The company reports suspicious transactions, including attempted ones, without delay and confidentially to the Financial Intelligence Unit (UIF) of the Costa Rican Drug Institute (ICD).
The AML/CFT risk assessment must be documented and kept up to date. Depending on the company's risks, SUGEF may require a compliance officer to be appointed or instead allow a different organisational structure.
In addition, due diligence thresholds and the conditions for meeting the obligations are set by a regulation of the National Council for the Supervision of the Financial System (CONASSIF). For virtual asset transfers, a VASP obtains and keeps information under the FATF standard, including the origin and destination of the transfer. Assets of persons on United Nations Security Council sanctions lists are frozen immediately. Companies with bearer shares may not be accepted as clients.
AML Requirements of Costa Rica and the EU: Comparison
| Criterion | Costa Rica (Law No. 10961) | EU (MiCA) |
|---|---|---|
| Permission to operate | Mandatory registration with SUGEF; it is not an authorisation to operate | Crypto-asset service provider (CASP) licence, Art. 59 and 62 |
| Territory | Costa Rica only | All EU countries through notification (Art. 65) |
| Office and management | Law No. 10961 contains no such requirements | Office and effective management in the EU, at least one director resident in the EU (Art. 59) |
| Register | Single VASP register at SUGEF; SUGEF may publish the lists | ESMA register (Art. 109) |
| Serving EU clients | Only at the client's own exclusive initiative (Art. 61 MiCA) | Active client acquisition is allowed |
| Sanctions | Fines of 2 to 100 base salaries or 5% to 50% of the transaction amount | Administrative penalties of national competent authorities (Art. 111) |
A comparison of MiCA and Costa Rican law shows that SUGEF registration does not give access to the EU market. If EU clients are the core of your business, you will need a CASP licence in one of the EU countries.
Transparency and Compliance Outside the EU
Transparency of transactions and investor protection outside the EU are achieved through corporate governance, internal control and regular due diligence. Costa Rican supervisors may exchange information with foreign regulators and conclude cooperation agreements. That is why managing reputational risks requires constant monitoring of legislative changes.
COREDO practice shows: blockchain analytics and an independent review of AML procedures make the dialogue with banks and supervisors easier.
Cryptocurrency Regulation: Costa Rica and the EU
In cryptocurrency regulation: Costa Rica and the EU, there are two different approaches to digital assets. Let us examine the main features of both models so that you can choose the right one for your project.
Main Differences in Approaches
MiCA has applied since 30 December 2024 and is built on licensing: the application is filed with the competent authority of an EU country. Costa Rica follows an AML/CFT supervision model: Licensing in the usual sense does not exist, but SUGEF registration is mandatory.
If an activity with virtual assets falls within the remit of another financial superintendency, the company is also subject to its regulation. A CONASSIF regulation may restrict obliged entities' transactions with VASPs that are not regulated for AML/CFT in any jurisdiction. When you work with EU clients, MiCA rules apply.
Risks of Operating Outside MiCA
Operating outside MiCA gives access to markets beyond the EU, but it also carries certain risks:
- EU clients may be served only at their own exclusive initiative.
- Advertising and soliciting clients in the EU without a CASP licence are not allowed.
- Banks in Costa Rica do not work with VASPs that lack a valid SUGEF registration.
- Possible difficulties with cross-border payments and integration with European payment systems.
A solution implemented by COREDO for one of its clients allowed minimizing legal risks by implementing international AML standards and engaging independent auditors to confirm transaction transparency.
Corporate Taxation and Governance
Income Tax Law No. 7092 is based on the territorial principle: profit tax is charged on activities of Costa Rican source. Since 2023, special rules have applied to passive foreign-source income of companies in multinational groups. That is why the tax effect of a structure should be checked before launch.
The COREDO team recommends building internal control and regular audit procedures into the structure at the registration stage to increase the trust of investors and partners.
Thus, a comprehensive approach to internal procedures will be the key to a successful launch and effective operation of the company in Costa Rica.
Launching a Cryptocurrency Company in Costa Rica
Launching a cryptocurrency company in Costa Rica now includes SUGEF registration and a working AML/CFT system from day one. Before scaling the business, it is important to consider the specifics of the local market and supervision to ensure a stable market entry.
Scaling the Business and Market Launch
Scaling a crypto business outside the EU requires a clear market entry strategy, integration with payment systems and KYC/AML procedures at the level of European standards. Choosing a reliable consulting partner becomes a key success factor.
The solution implemented by COREDO includes comprehensive support at all stages - from selecting the optimal corporate structure to assistance with account opening and blockchain analytics integration.
How to Reduce Legal and Reputational Risks
Legal risks when registering a crypto company in Costa Rica are minimised through:
- Timely SUGEF registration and updating of its data.
- Extended due diligence of all participants.
- Regular audits of transactions and a transparent corporate structure.
- Constant monitoring of sanctions lists and suspicious transactions.
The COREDO team supports clients at all stages, helping to build a reputational risk management system and ensure the company's legal integrity.
Mistakes in Choosing a Jurisdiction
A typical mistake is to rely on outdated reviews that describe Costa Rica as a country without requirements for crypto businesses. The second mistake is to assume that a Costa Rican registration allows active acquisition of EU clients. The third is a formal approach to compliance. For failure to meet the obligations and for refusing to register, SUGEF imposes fines of 2 to 100 base salaries.
COREDO's experience shows: careful preparation and a comprehensive approach to compliance help avoid most mistakes and ensure the long-term sustainability of the business.
Main Conclusions and Recommendations
A cryptocurrency company in Costa Rica is not a way around MiCA but a national regime with mandatory SUGEF registration and AML/CFT supervision. It suits projects that operate in markets outside the EU. When choosing a jurisdiction, base the decision on a risk assessment, a transparent corporate structure and readiness to comply with AML/KYC standards.
COREDO practice confirms: comprehensive business support, due diligence implementation, and constant monitoring of regulatory changes allow not only the legalization of crypto business in Latin America but also ensure its long-term sustainability and investment attractiveness.
If your goal is a crypto business outside the EU, Costa Rica remains a workable jurisdiction provided you register with SUGEF. Active work with EU clients requires a MiCA licence. The COREDO team is ready to offer practical solutions tailored to the specifics of your project.