Costa Rica Crypto Compliance Cost Calculator
Estimate your annual compliance costs for operating a crypto business in Costa Rica under the new regulatory framework.
- Registration with SUGEF
- AML/CFT compliance systems
- Compliance officer salary
- Transaction monitoring infrastructure
When you read headlines about Latin America and crypto, you often see bold moves like El Salvador’s Bitcoin law. Costa Rica, however, has taken a very different path - it still does Costa Rica cryptocurrency regulation that does not treat digital coins as legal tender. The result is a gray‑zone environment where crypto firms can operate, but only under strict anti‑money‑laundering (AML) and counter‑terrorist‑financing (CFT) rules.
Legal Status: No Official Recognition
Costa Rica is a Central American nation whose central bank explicitly states that cryptocurrencies are not legal tender, monetary currency, or foreign currency. This declaration comes from the Central Bank of Costa Rica (Banco Central de Costa Rica) and has been reaffirmed in every official communication up to July 2025.
Meanwhile, Cryptocurrency is defined as a digital representation of value that can be traded online but lacks legal‑tender status in Costa Rica. The country therefore avoids the extremes of outright bans (like China) and full adoption (like El Salvador).
Emerging Regulatory Framework
Since December 2021 the Costa Rican government has drafted two key bills that shape the crypto landscape:
- Bill 22.837 - the “Cryptoassets Market Law” aims to amend Law No. 7786 (the anti‑money‑laundering statute) and introduces a specific definition for virtual assets and Virtual Asset Service Providers (VASPs).
- Bill 23.415 - a complementary proposal that fine‑tunes licensing, consumer‑protection, and reporting obligations for VASPs.
Both bills passed their first legislative debate in July 2025 and are expected to be finalized by late 2025. Until then, the regulatory environment remains a hybrid of existing AML rules and the nascent crypto‑specific provisions.
Who Regulates What? The Role of SUGEF
The Superintendencia General de Entidades Financieras (SUGEF) is the primary supervisory authority for crypto‑related activities. SUGEF requires any entity that performs at least one of the following to register as a VASP:
- Exchange between virtual assets and legal tender (or between virtual assets).
- Transfer of virtual assets on behalf of third parties.
- Custody, administration, or safekeeping of virtual assets.
- Issuance, marketing, or promotion of virtual assets.
Registration does not constitute a government licence to operate - it merely signals that the entity has disclosed its activities and agreed to comply with SUGEF’s AML/CFT standards.
Compliance Checklist for VASPs
Operating in Costa Rica demands a robust compliance program. Below is a practical checklist that most crypto startups use:
- Develop written AML/CFT policies covering customer due diligence, transaction monitoring, and record‑keeping.
- Implement a KYC platform that can handle at least 1,000 transactions per hour (the benchmark cited by ZIGRAM’s July 2025 analysis).
- Appoint a dedicated compliance officer - 65 % of local VASPs report having one full‑time staff member.
- Perform risk assessments for politically exposed persons (PEPs) and high‑risk jurisdictions.
- Maintain transaction logs for a minimum of five years, accessible to SUGEF on request.
- Submit periodic AML reports and cooperate with any on‑site inspections.
Cost estimates range from USD 25,000 to 75,000 for initial setup, with ongoing compliance budgets of roughly USD 10,000 per year for a midsize operation.
Business Impact: Opportunities and Pain Points
Despite the lack of official recognition, Costa Rica offers several advantages that attract crypto entrepreneurs:
- Tax incentives - low corporate tax rates for foreign‑direct investment.
- Political stability - a democratic system with strong rule of law.
- Tech‑friendly infrastructure - widespread broadband and a growing pool of software engineers.
On the flip side, founders consistently report two major hurdles:
- Banking access - traditional banks often reject crypto‑related accounts, forcing companies to spend 6‑8 months courting smaller institutions.
- Regulatory certainty - the pending bills create ambiguity, especially around consumer‑protection measures.
RUE.EE’s 2025 guide notes that company registration takes 30‑45 days, but securing a bank relationship can stretch the timeline to a year.
How Costa Rica Stacks Up Against Neighbours
| Aspect | Costa Rica | El Salvador | Panama |
|---|---|---|---|
| Legal tender status | No | Bitcoin legal tender (2021) | No, sandbox regime |
| Primary regulator | SUGEF (financial supervisor) | Superintendencia del Sistema Financiero | Autoridad de Supervisión del Sistema Financiero |
| VASP registration required | Yes (does not confer licence) | Yes (licensed under Bitcoin law) | Yes (sandbox permits) |
| AML/CFT framework | FATF‑aligned, pending Bill 22.837 | FATF‑aligned, but limited enforcement | FATF‑aligned, active sandbox compliance |
| Banking openness for crypto firms | Limited - most major banks reluctant | Similar challenges, some state‑backed banks | Better - several banks participate in sandbox |
| Market size (2025) | ≈ USD 1.2 bn | ≈ USD 3.5 bn | ≈ USD 0.9 bn |
The table shows that Costa Rica opts for a cautious, compliance‑first model. It may lack the headline‑grabbing policies of El Salvador, but it also avoids the regulatory backlash seen in more restrictive jurisdictions.
Future Outlook: What to Watch for in 2025‑2026
Two legislative milestones will shape the next 12‑months:
- Final passage of Bill 22.837 - expected by October 2025. This will lock in VASP registration rules and specify AML reporting thresholds.
- Adoption of Bill 23.415 - likely early 2026, providing a clearer consumer‑protection regime and potentially a sandbox for fintech innovators.
In parallel, SUGEF plans a $2.3 million upgrade to its KYC platform (Q4 2025), which should streamline onboarding for compliant firms. EY projects full alignment with FATF standards by mid‑2026, turning Costa Rica into a regional hub for “clean” crypto operations.
However, two risk factors remain:
- Banking sector readiness - 43 % of surveyed banks still lack the technical infrastructure to support crypto accounts.
- Implementation lag - if legislation stalls, the country could lose the momentum that recent tax‑incentive reforms have generated.
For entrepreneurs, the practical advice is simple: set up your compliance framework now, secure a niche banking partner, and monitor the legislative calendar closely. Those who move early can lock in the tax benefits while the regulations solidify.
Key Takeaways
- Costa Rica does not treat crypto as legal tender but permits VASPs under AML/CFT rules.
- SUGEF is the main regulator; registration is mandatory but not a licence.
- Compliance costs are significant, but tax incentives and political stability make the market attractive.
- Banking access remains the toughest hurdle for new crypto businesses.
- Watch for Bill 22.837’s final approval and the rollout of SUGEF’s upgraded KYC system.
Is Bitcoin legal tender in Costa Rica?
No. The Central Bank of Costa Rica has repeatedly confirmed that cryptocurrencies are not recognized as legal tender, monetary currency, or foreign currency.
Do crypto businesses need a license to operate?
They must register with SUGEF as a Virtual Asset Service Provider (VASP). Registration is mandatory but does not grant a government licence; it only obliges firms to follow AML/CFT rules.
What are the main AML requirements?
Firms must conduct customer due diligence, monitor transactions (minimum 1,000 tx/hr capacity), keep records for five years, and report suspicious activity to SUGEF.
How hard is it to open a bank account?
Very challenging. Most major banks refuse crypto‑related accounts, forcing businesses to seek smaller institutions willing to work under strict monitoring. The process can take 6‑8 months.
When will the new crypto bills be finalized?
Bill 22.837 is expected to pass by October 2025, while Bill 23.415 should be ready for a vote in early 2026.
18 Comments
MICHELLE SANTOYO
So let me get this straight - they don't even call it money but let you run exchanges like a backyard lemonade stand? That's not regulation, that's just ignoring it until it blows up. I love it.
Herbert Ruiz
The regulatory framework is insufficiently defined. Without clear statutory authority, VASP registration is legally meaningless.
Saurav Deshpande
They say they're not banning it but they're making it so expensive to comply that only big banks can afford it. Classic. They're not protecting consumers - they're protecting the old system. The Central Bank is just scared of losing control.
Paul Lyman
Yo if you're starting a crypto biz in Costa Rica DO IT. The tax breaks are insane and the engineers are solid. Yeah banking is a nightmare but find a small credit union - they’re hungry for new clients. Just don’t skip the KYC - SUGEF will find you. You got this 💪
Frech Patz
Is there any documented case of a VASP being penalized under the current AML/CFT framework prior to the passage of Bill 22.837?
Derajanique Mckinney
why do they even bother?? like i get the whole 'no legal tender' thing but then u make them pay 75k to register?? smh. 🤦♀️
Rosanna Gulisano
This is how you kill innovation. Letting people operate in a gray zone is just inviting fraud
Sheetal Tolambe
I think Costa Rica’s approach is actually smart. Not jumping into Bitcoin like El Salvador, but building real guardrails. It’s slow but it might last longer. Hope they get the banking part figured out soon
gurmukh bhambra
You know who’s really behind this? The IMF. They told Costa Rica not to let crypto loose. They don’t want people to escape the dollar system. This is all control. The ‘AML rules’? Just a cover. Watch what happens after 2026.
Sunny Kashyap
India does better. We ban it. Simple. No confusion. No fake compliance. No 75k scams.
james mason
Honestly, the fact that you need a compliance officer just to send Bitcoin is a joke. This isn’t finance - it’s bureaucracy theater. I’d rather run a DAO from my garage than deal with this.
Anna Mitchell
I really admire how they’re trying to balance innovation and safety. It’s not perfect but it’s thoughtful. Hope more countries take this route instead of panic bans or reckless adoption.
Jean Manel
The $2.3M KYC upgrade is a red flag. That’s not for compliance - that’s for surveillance. They’re building a financial firewall. You think this is about AML? It’s about tracking every Satoshi. Wake up.
William P. Barrett
There’s something beautiful about a country refusing to turn crypto into a state religion. It doesn’t need to be legal tender to be valuable. The real question isn’t whether it’s money - it’s whether it’s free. And in Costa Rica, at least for now, it still is.
Cory Munoz
I get how hard banking is. I had a friend go through it last year. Took 10 months. But he found this tiny bank in San Jose that just wanted to learn. Sometimes the smallest places are the most open. Just be patient and show them your docs. They’ll get it.
Jasmine Neo
This is a regulatory farce. AML is a pretext. The real goal is to monopolize the crypto space under state-approved entities. The 'tax incentives'? A bait. The 'political stability'? A lie. They want to control the narrative. Watch the first VASP get quietly shut down after October 2025.
Ron Murphy
The Panama comparison is interesting - their sandbox model seems more adaptive. Costa Rica’s approach feels like walking through molasses. Still, the FATF alignment is a solid foundation. Just needs faster execution.
Prateek Kumar Mondal
If you build it right the compliance will become the advantage. Most countries are chaos. Costa Rica is slow but clean. That’s worth more than hype. Just focus on the long game