Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Costa Rica CR

Domains (D1–D6)
4
Sources
15
Role actions
8
Horizon <90d
2
Jurisdiction profile
CleanTier BRisk: IncreasingMixed

Costa Rica's AML/CFT regime rests on Law 7786 (as amended), supervised by SUGEF/CONASSIF for financial institutions and by the DNN and SUGEF for DNFBPs, with a non-public beneficial-ownership registry (RTBF, Decree 41040-H) and FIU functions housed within the Costa Rican Drug Institute (ICD).

MoreGAFILAT's Fourth Round enhanced follow-up (Feb 2024) recorded technical-compliance upgrades (R17 to Compliant; R22, R28 to Largely Compliant) but flagged residual DNFBP customer-due-diligence gaps ahead of the Fifth Round evaluation.

Key deficiencies
  • DNFBP (notary/lawyer/accountant) CDD gaps for company-formation 'contributions' under Recommendation 22
  • Free-trade-zone and Caribbean port customs oversight vulnerable to trade-based money-laundering concealment in agricultural export flows
  • Non-public beneficial-ownership registry (RTBF) whose effectiveness remains untested ahead of the Fifth Round evaluation
  • Absence of a dedicated virtual-asset service provider (VASP) licensing and supervisory regime
Recent developments (18m)
  • OFAC designated a Costa Rican narcotrafficking network and an affiliated law firm under EO 14059 (Aug 2025)
  • OFAC designated the Picado Grijalba narcotics-trafficking network and Costa Rican front companies (Jan 2026)
  • Costa Rica's OIJ arrested ex-Security Minister/Supreme Court Justice Celso Gamboa Sánchez on a US drug-trafficking extradition request (Jun 2025)
  • Legislative Assembly narrowly failed to strip President Chaves' immunity over an alleged influence-peddling investigation (Sept 2025)
  • EU Commission's Dec 2025 high-risk third-country list update did not add Costa Rica, keeping it off the EU HRTC list
Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

Costa Rica enacted its first AML/CFT registration perimeter for virtual asset service providers this cycle. Law N.246 10961, published in La Gaceta Alcance N.246 78 on 19 June 2026, added Article 15 quater to Law 7786, the countrys core AML/CFT statute, obliging VASPs engaged in exchange, transfer, custody or control, or issuance-related financial services to register with SUGEF and comply with AML/CFT/CPF duties. The provision entered into force around 19 September 2026, three months after publication. Registration is explicitly not an operating licence, a structural choice that closes part of the FATF Recommendation 15 gap for virtual assets while leaving authorisation-level scrutiny thinner than a full licensing regime would provide. CONASSIF, the financial-system oversight body, is due to publish implementing regulations covering thresholds, scope, exclusions and technical requirements within three months of entry into force, expected around the fourth quarter of 2026; that regulation has not yet been published.

Other Developments

Penalty schedule under amended Article 81 is substantial. Breach of registration, customer-due-diligence or reporting duties under Article 15 quater carries penalties of 5% to 50% of the transaction amount, or 2 to 100 base salaries, scaled to gravity and recidivism, under Law 7786 Article 81 as amended by Law 10961 Article 3. Beneficial-ownership filing extension remains unconfirmed. Secondary legal commentary states that VASPs will also need to file annually into Costa Ricas existing Transparencia y Beneficiarios Finales beneficial-ownership registry with the Central Bank, extending BO-registry coverage to the new VASP population as Article 15 quater is implemented; this has not been independently confirmed against the gazette text. Illicit trade flagged as the countrys top criminal-financing channel. Costa Ricas Chamber of Commerce, through its Illicit Trade Observatory, estimated 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 rests on a single Tier-3 press account relaying a non-governmental trade-association estimate rather than a primary government or Chamber report. GAFILAT evaluation calendar shows forward movement. FATFs global assessment calendar lists a possible onsite period for Costa Ricas 5th-round mutual evaluation in November 2026 and a possible plenary discussion in July 2027, which would be the first assessment of the new VASP registration perimeters real-world effectiveness; Costa Ricas 4th-round evaluation rated it Compliant on 17 and Largely Compliant on 20 of the 40 FATF Recommendations, with no current grey-list status.

Cross-Monitor Connections

The same statutory event is tracked by the crypto monitor as a licensing-and-classification development and by the world-payments monitor as a correspondent-banking consequence: Law 7786, as amended, now bars SUGEF-regulated banks from maintaining commercial relationships with VASPs required to register under Articles 15, 15 bis, 15 ter or 15 quater who are not duly registered. That banking-access bar functions as a de-risking lever independent of the underlying AML substance, and operators unable to register promptly face a practical banking-access consequence layered on top of the AML registration duty itself.

Outlook

The near-term marker is CONASSIFs implementing regulation, expected in the fourth quarter of 2026, which will determine the practical scope of SUGEFs VASP register, including de minimis thresholds and technical and fit-and-proper requirements. Over a longer horizon, the possible GAFILAT onsite in November 2026 and plenary discussion in July 2027 would provide the first independent assessment of whether the registration-without-licensing model closes the Recommendation 15 gap in substance as well as in statute. Whether the RTBF beneficial-ownership extension to VASPs is confirmed, and whether the Chamber of Commerce illicit-trade estimate is corroborated by a primary source, remain open questions that would sharpen Costa Ricas enabler-jurisdiction risk profile if resolved.

weekly_brief_draft · JID CR
Domain intelligence (D1–D6)

D1 Sanctions

Not covered

Sanctions is not yet covered for this jurisdiction in this report.

D2 Beneficial Ownership and Corporate Transparency

Beneficial Ownership and Corporate Transparency

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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.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

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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.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto, Digital Assets, and Financial Innovation

Crypto, Digital Assets, and Financial Innovation

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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.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

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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.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
Consultation2026-Q4 · ±quarter

CONASSIF implementing regulation for Art. 15 quater (Law 7786) VASP thresholds

CONASSIF is expected to specify the practical scope of SUGEF's VASP register, including de minimis thresholds and technical/fit-and-proper requirements, within three months of the law's 19 September 2026 entry into force.
Proposed2027-Q3 · ±year

GAFILAT 5th-round mutual evaluation of Costa Rica

A possible onsite visit (Nov 2026) and plenary discussion (Jul 2027) would produce Costa Rica's next full mutual evaluation report under the 2022 Methodology.
2 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

Costa Rica created a new VASP AML registration duty under SUGEF with penalties up to 50% of transaction value.

Institutions with Costa Rican VASP counterparties or correspondent exposure should note that counterparties must now register with SUGEF under Article 15 quater, with non-registration itself now a red flag given the statutory penalty regime and the accompanying banking-access bar.

2 evidence refs
Compliance

CONASSIF's implementing regulation for VASP registration thresholds remains unpublished pending a Q4 2026 deadline.

Compliance functions assessing Costa Rican VASP counterparties currently have a statutory registration duty to screen for but no published technical thresholds or exclusions to calibrate risk-based due diligence against until CONASSIF publishes.

1 evidence refs
Legal

Registration under Article 15 quater is explicitly not an operating licence, and a new banking-access bar attaches to non-registration.

Legal teams should distinguish the registration duty from any authorisation concept, and note the statutory bar on SUGEF-regulated banks maintaining relationships with unregistered persons required to register under Articles 15, 15 bis, 15 ter or 15 quater.

1 evidence refs
Board

Costa Rica's illicit-trade channel is estimated at approximately US$3.6 billion, flagged as the country's top source of criminal financing.

Boards overseeing exposure to Costa Rica should be aware of a domestic estimate, not yet independently corroborated, that places illicit trade ahead of other channels as the principal source of criminal financing in the country, alongside the country's upcoming GAFILAT mutual evaluation cycle.

2 evidence refs
CTO

Costa Rica's VASP AML registration regime creates a new counterparty-screening data point tied to SUGEF registration status.

Technology teams building counterparty-screening or transaction-monitoring logic for Costa Rican VASP exposure should plan for a SUGEF-registration status field, noting that CONASSIF's technical requirements and thresholds are not yet published.

2 evidence refs
Risk

Costa Rica's enabler-jurisdiction risk trajectory is mixed: AML tightening in the VASP sector against a large flagged illicit-trade channel.

Risk functions should weight the formal tightening of VASP AML registration against the uncorroborated but substantial illicit-trade estimate when calibrating Costa Rica's jurisdiction risk score, and monitor the RTBF beneficial-ownership extension question as a secondary signal.

2 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

Costa Rica's GAFILAT 5th-round evaluation calendar shows a possible onsite in November 2026 and plenary in July 2027.

Audit functions should note the upcoming mutual-evaluation cycle as the first independent effectiveness test of the new VASP registration perimeter, relevant to documenting control-testing scope for Costa Rica-exposed obliged entities.

1 evidence refs
Decision lens
MLRO

Costa Rica created a new VASP AML registration duty under SUGEF with penalties up to 50% of transaction value.

Compliance

CONASSIF's implementing regulation for VASP registration thresholds remains unpublished pending a Q4 2026 deadline.

Legal

Registration under Article 15 quater is explicitly not an operating licence, and a new banking-access bar attaches to non-registration.

Board

Costa Rica's illicit-trade channel is estimated at approximately US$3.6 billion, flagged as the country's top source of criminal financing.

CTO

Costa Rica's VASP AML registration regime creates a new counterparty-screening data point tied to SUGEF registration status.

Risk

Costa Rica's enabler-jurisdiction risk trajectory is mixed: AML tightening in the VASP sector against a large flagged illicit-trade channel.

Operations

No material change this cycle.

Audit

Costa Rica's GAFILAT 5th-round evaluation calendar shows a possible onsite in November 2026 and plenary in July 2027.

Shared evidence: 4 refs
Scenario sketches

AMLA transition and cross-border obliged-entity supervision

Illustrative orientation only: as the EU moves from purely national AML supervision toward AMLA direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly-applicable AMLR (Reg 2024/1624) and per-state 6AMLD transposition, the supervisory perimeter for large cross-border groups could tighten in ways that indirectly affect correspondent and counterparty relationships with non-EEA jurisdictions such as Costa Rica, for example through enhanced due-diligence expectations placed on EU-supervised banks dealing with newly registered VASP counterparties abroad. This is architecture-over-incident framing, not a prediction about Costa Rica specifically.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion ArchitecturestableNo Costa Rica-specific Russian sanctions-evasion, dark-fleet, tech-procurement or UN Panel/OFAC/OFSI Yemen-Houthi nexus found this cycle.
T2 · EU AML Package / AMLAno_changeNot directly applicable: Costa Rica is autonomous and non-EEA, not bound by AMLR/6AMLD/AMLA.
T3 · FATF Grey ListwatchCosta Rica remains off the FATF grey list; FATF's calendar lists a possible 5th-round onsite in Nov 2026 and plenary discussion Jul 2027 -- the first forward movement on CR's assessment cycle visible this period.
T4 · Beneficial-Ownership Register StatuswatchSecondary commentary (not independently confirmed) states VASPs will also need to file Costa Rica's RTBF beneficial-ownership registry annually with the Central Bank.
T5 · Crypto & Digital-Asset Integritymaterial_changeLaw 10961 (Art. 15 quater, Law 7786) entered into force on or around 19 September 2026, creating Costa Rica's first AML/CFT registration perimeter for VASPs under SUGEF, closing part of the FATF R.15 gap. CONASSIF's implementing regulation is due within three months of entry into force.
T6 · Sanctions Regime DivergencestableNo new OFAC, OFSI or EU-Council designation affecting Costa Rica found within this cycle's window.
Registers

Enforcement actions

  • OFAC designated a network of notorious Costa Rican narcotics traffickers, including individuals based in Limón and San José, and an affiliated Costa Rican law firm, under Executive Order 14059 for their role in illicit drug trafficking. 18 Aug 2025
  • OFAC designated one of the Caribbean's largest narcotics traffickers, Luis Manuel Picado Grijalba, along with family members and several Costa Rican shell entities (a fishing association, a beauty salon, real-estate SAs) used to front and launder trafficking proceeds. 22 Jan 2026
  • Costa Rica's judicial police arrested former Security Minister and Supreme Court Justice Celso Gamboa Sánchez, together with an alleged accomplice, on a US DEA extradition request related to international drug trafficking, highlighting the penetration of narco-linked professional/political networks into senior state institutions. 23 Jun 2025

Sanctions changes

  • OFAC added Costa Rican narcotics-trafficking individuals and an affiliated law firm to the SDN list under the counter-narcotics EO 14059 program. 18 Aug 2025
  • OFAC designated the Picado Grijalba trafficking network and associated Costa Rican front companies under the illicit-drugs EO 14059 program. 22 Jan 2026
  • The European Commission's December 2025 update to the EU list of high-risk third countries (Delegated Regulations (EU) 2026/46 and 2026/83) added Russia, Bolivia and the British Virgin Islands and delisted several African states, but did not add Costa Rica, despite its recurrent appearance in US counter-narcotics money-laundering designations. 4 Dec 2025

Regulatory horizon (register)

  • GAFILAT Fifth Round Mutual Evaluation of Costa Rica
  • Next EU high-risk third-country list update cycle
  • Next US State Dept INCSR Vol. II money-laundering jurisdiction review

Active schemes

  • [HIGH] Cocaine trans-shipment concealed in Costa Rican agro-exports
  • [HIGH] Shell-company front networks laundering narco-proceeds
  • DNFBP gatekeeping gaps and regional 'banana route' laundering
  • Cross-border bank-stake acquisition using alleged fraud proceeds
Sources
  1. FATF
  2. GAFILAT / FATF
  3. FATF
  4. FATF
  5. US Treasury OFAC
  6. US Treasury OFAC
  7. European Commission (DG FISMA)
  8. UNODC / UNCAC Implementation Review Group
  9. OCCRP
  10. Bloomberg
  11. OCCRP
  12. OCCRP
  13. Bloomberg
  14. ICIJ
  15. FATF
Coverage gaps
Despite UNODC Container Control Programme training and port …
Despite UNODC Container Control Programme training and port scanning capacity-building, Costa Rica's Caribbean ports and free-trade-zone logistics chains remain a primary conduit for cocaine trans-shipment concealed in legitimate agro-exports, with a $70 million cocaine seizure inside a Costa Rica-origin pineapple shipment in Spain in late 2025.
GAFILAT's 2024 enhanced follow-up found that Costa Rica's DN…
GAFILAT's 2024 enhanced follow-up found that Costa Rica's DNFBP regulation for notaries, lawyers and accountants does not explicitly cover situations where such professionals organise 'contributions' for the creation, operation and management of companies, leaving Recommendation 22 only partially addressed even after re-rating.
In September 2025 Costa Rica's Legislative Assembly voted 34…
In September 2025 Costa Rica's Legislative Assembly voted 34-21 to strip President Rodrigo Chaves' immunity over an alleged influence-peddling investigation — a majority, but short of the two-thirds threshold required — leaving the sitting executive shielded from prosecution ahead of the 2026 general election.
No dedicated Costa Rican VASP/crypto-asset licensing framewo…
No dedicated Costa Rican VASP/crypto-asset licensing framework, nor sector-specific national risk-assessment publications for private banking, TCSP or fund management, were located in this baseline research pass; sector_rna_urls is left empty pending targeted follow-up.

Evidence

Confidence-tiered claims

Virtual asset service providers (exchange, transfer, custody/control, issuance-related financial services) must register with SUGEF; registration is not an operating licence. Law entered into force ~19 September 2026. SRC-fim-CR-001
Probable · 1 source
Penalties of 5%-50% of transaction amount, or 2-100 base salaries, for registration/CDD/reporting failures under Art. 15 quater. SRC-fim-CR-002
Probable · 1 source
CONASSIF must issue implementing regulations for Art. 15 quater (thresholds, scope, exclusions, technical requirements) within three months of entry into force (~December 2026); not yet published as of this cycle. SRC-fim-CR-006
Probable · 1 source
Possible onsite period November 2026 and possible plenary discussion July 2027 under Costa Rica's 5th-round mutual evaluation (2022 Methodology). SRC-fim-CR-004
Probable · 1 source
Illicit trade estimated at approximately CRC 1.6 trillion (~US$3.6bn), described as Costa Rica's principal source of criminal financing, alongside an estimated CRC 664bn (~US$1.5bn) in forgone tax revenue; reported 10 September 2026. SRC-fim-CR-008
Uncertain · 1 source
VASPs will reportedly need to file Costa Rica's existing Transparencia y Beneficiarios Finales (RTBF) beneficial-ownership registry annually with the Central Bank, extending BO-registry coverage to the new VASP population; not independently confirmed against the gazette text. SRC-fim-CR-007
Uncertain · 1 source