Costa Rica CR

Costa Rica sits outside the European Unions AML Package architecture: the AML Regulation (Regulation (EU) 2024/1624, directly applicable), the sixth AML Directive (6AMLD, transposed per Member State), and the AMLA Regulation (Regulation (EU) 2024/1620) establishing the Anti-Money Laundering Authority form a structural backdrop for EU and EEA jurisdictions, shifting supervision toward a hybrid EU-level regime, but Costa Rica is autonomous and non-EEA and is not bound by that architecture. In Costa Rica, the directly relevant beneficial-ownership development this cycle is narrower and locally sourced: secondary legal commentary, not yet corroborated against the gazette text of Law 10961, states that virtual asset service providers will also need to file annually into Costa Ricas existing Transparencia y Beneficiarios Finales (RTBF) registry, administered by the Central Bank, as the countrys new Article 15 quater VASP registration regime is implemented. If confirmed, this would extend an existing beneficial-ownership filing mechanism to a newly regulated population rather than create a new registry. Until a primary regulatory or statutory source confirms the extension, it remains an open question whether RTBF coverage of VASPs follows automatically from VASP status or requires separate implementing action by CONASSIF or the Central Bank.

Globally, the EU AML Package sets the structural direction for beneficial-ownership transparency architecture that other jurisdictions are sometimes measured against informally, but in Costa Rica the operative question is this narrower, locally specific RTBF extension rather than any EU-aligned transposition exercise.

Outlook

Confirmation or denial of the RTBF-VASP filing extension against the primary gazette text or a CONASSIF implementing regulation would resolve the single open beneficial-ownership question in Costa Rica this cycle. Absent that confirmation, the extension should be treated as reported but unverified.

Costa Ricas enabler-jurisdiction risk profile shows a mixed trajectory this cycle. On the tightening side, Law 10961s registration-without-licensing model for virtual asset service providers closes part of the long-standing FATF Recommendation 15 gap: VASPs must now register with SUGEF and comply with AML/CFT/CPF duties under Article 15 quater of Law 7786, in force around 19 September 2026. That said, the registration-without-licensing design leaves authorisation-level scrutiny thinner than a full licensing gate would provide, and CONASSIFs implementing regulation on thresholds, scope and technical requirements remains unpublished pending a three-month statutory deadline from entry into force.

On the enablement side, a domestic estimate from Costa Ricas Chamber of Commerce, through its Illicit Trade Observatory, placed illicit trade at approximately CRC 1.6 trillion, roughly US$3.6 billion, reported 10 September 2026 as the countrys principal source of criminal financing, alongside an estimated CRC 664 billion, roughly US$1.5 billion, in forgone tax revenue. This estimate rests on a single Tier-3 press account relaying a non-governmental trade-association figure, not a primary government report, which caps the finding at an uncertain confidence level pending independent corroboration.

Read together, the statutory tightening in the virtual-asset sector and the scale of the illicit-trade estimate describe a jurisdiction where formal AML architecture is being built out even as a large informal channel for criminal financing is independently flagged by a domestic business association.

Outlook

Whether the Chamber of Commerce illicit-trade estimate is corroborated by a primary government or association report, and whether CONASSIFs implementing regulation narrows or widens the practical reach of VASP registration, are the two developments most likely to move Costa Ricas enabler-jurisdiction risk assessment in either direction.

Costa Ricas Legislative Assembly unanimously passed Expediente 25.340, published as Law N.246 10961 in Alcance N.246 78 to La Gaceta N.246 113 on 19 June 2026, adding Article 15 quater to the AML/CFT statute Law 7786. The article defines virtual asset and virtual asset service provider and obliges VASPs -- covering exchange, transfer, custody or control, and issuance-related financial services -- to register with SUGEF and comply with AML/CFT/CPF duties. Registration is explicitly stated not to constitute an operating licence. The law entered into force three months after publication, around 19 September 2026, with CONASSIFs implementing regulation due a further three months after that, expected around the fourth quarter of 2026 and not yet published as of this cycle.

Penalties for breach of registration, customer-due-diligence or reporting duties under amended Article 81 run 5% to 50% of the transaction amount, or 2 to 100 base salaries, scaled to gravity and recidivism. This is Costa Ricas first dedicated AML/CFT perimeter for virtual assets, closing part of the FATF Recommendation 15 gap for the sector, though the registration-without-licensing structure means CONASSIFs forthcoming technical regulation will determine much of the regimes practical substance: thresholds, scope, exclusions and fit-and-proper requirements remain unpublished.

Outlook

CONASSIFs implementing regulation, expected in the fourth quarter of 2026, is the single most consequential near-term development for Costa Ricas digital-asset AML architecture, converting a statutory registration duty into an operative regime with defined technical parameters.

Costa Ricas core AML/CFT statute, Law 7786, was materially amended this cycle by Law N.246 10961, adding Article 15 quater to bring virtual asset service providers into the registration perimeter administered by SUGEF. Penalties under amended Article 81 for breach of registration, customer-due-diligence or reporting duties run 5% to 50% of the transaction amount, or 2 to 100 base salaries, scaled to gravity and recidivism. The provision entered into force around 19 September 2026, and CONASSIFs implementing regulation on thresholds, scope, exclusions and technical requirements is due within three months of that date, not yet published.

A separate consequence of the same amendment bars SUGEF-regulated banks from maintaining commercial relationships with persons required to register under Articles 15, 15 bis, 15 ter or 15 quater who are not duly registered, functioning as a banking-access lever independent of the underlying AML substance.

On the assessment-cycle front, FATFs global calendar lists a possible onsite period for Costa Ricas 5th-round mutual evaluation in November 2026 and a possible plenary discussion in July 2027. Costa Ricas 4th-round mutual evaluation, from July 2015, and its enhanced follow-up from February 2024, rated the country Compliant on 17 and Largely Compliant on 20 of the 40 FATF Recommendations, with no current FATF grey-list status. The possible 5th-round onsite would be the first independent test of whether the new VASP registration perimeter closes the Recommendation 15 gap in effectiveness terms, not just on paper.

Outlook

The possible GAFILAT onsite in November 2026, followed by a possible plenary discussion in July 2027, is the key date to watch for an independent effectiveness assessment of Costa Ricas amended AML/CFT regime, including the new VASP registration perimeter.