Costa Rica

**Superintendencia General de Entidades Financieras (SUGEF):** The General Superintendency of Financial Institutions. SUGEF is responsible for supervising financial entities and enforcing AML/CFT regulations for many obligated subjects.

Virtual asset service providers in Costa Rica are not yet explicitly classified as 'obligated subjects' under Law 7786; the proposed amendment (Expediente 22.837) that would explicitly include them remains pending and has faced procedural setbacks.

**Registration:** With SUGEF as an "obligated subject" (if the activity falls under their scope) or potentially with the Financial Intelligence Unit (Unidad de Inteligencia Financiera - UIF) depending on the exact classification.

**Full AML/KYC Program:** Implementation of robust Know Your Customer (KYC), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Transaction Monitoring policies and procedures.

**AML Officer:** Appointment of a designated AML Compliance Officer.

**Reporting:** Obligation to report suspicious transactions (SARs/STRs) to the UIF.

**Record-keeping:** Maintenance of transaction and client records for a specified period.

**Risk Assessment:** Conduct a comprehensive money laundering and terrorism financing risk assessment.

**Status:** If the custody provider holds virtual assets on behalf of clients and/or provides services that enable the transfer or exchange of these assets, they would likely also fall under the "obligated subject" category, especially if they control the private keys for clients.

**Requirements:** Similar to exchanges – full AML/KYC program, AML officer, reporting, record-keeping, risk assessment.

**If processing fiat currency payments (even if crypto-related):** They would likely fall under existing payment service provider regulations and certainly under AML/CFT laws as obligated subjects.

**If purely crypto-to-crypto transactions (e.g., facilitating payments in crypto without fiat conversion):** This remains a grey area in many jurisdictions without specific VASP licensing. However, the global trend is to bring such services under AML/CFT scrutiny if they involve value transfer and could be used for illicit purposes. SUGEF's interpretation would be key.

**Requirements:** Similar to exchanges and custody providers if deemed an obligated subject. Additionally, if they handle fiat, they might need to comply with general financial service regulations, which could entail higher capital requirements and specific operational licenses from SUGEF, depending on the scope of fiat activities.

**Capital Requirements:** There are no specific capital requirements *for crypto-specific licenses* as such licenses don't exist. However:

If an entity's operations are interpreted as falling under the scope of existing financial institution activities (e.g., holding client funds, providing certain payment services in fiat), then the capital requirements applicable to traditional financial institutions or payment service providers regulated by SUGEF would apply. These can vary significantly depending on the type of financial service.

For entities purely operating as "obligated subjects" under AML without being a licensed financial institution, there isn't a direct prescribed minimum capital, but demonstrating financial soundness and having adequate resources to implement AML controls is implicitly expected.

**AML/KYC Requirements:** This is the most crucial aspect. Obligated subjects must implement comprehensive AML/CFT programs that include:

Customer identification and verification (KYC).

Ongoing monitoring of business relationships.

Identification and reporting of suspicious transactions.

Internal controls, policies, and procedures.

Designation of a compliance officer.

**Local Presence:** Generally, any company operating and generating income in Costa Rica needs to be incorporated locally and have a local registered office and local representation (e.g., a local legal representative). This is standard corporate law, not crypto-specific. For AML purposes, having a local AML officer is also typical.

**Legal Opinion/Classification:** Obtain a legal opinion to determine if the specific business model falls under the definition of an "obligated subject" according to Ley 7786 and its implementing regulations (e.g., SUGEF Agreement 13-10).

**Company Incorporation:** Incorporate a legal entity in Costa Rica.

**Registration with SUGEF/UIF:** If classified as an obligated subject, register the entity with the relevant authority (SUGEF or UIF, depending on the exact classification and type of obligated subject).

**AML Program Development:** Develop and implement a robust AML/CFT manual, policies, and procedures tailored to the specific business and its identified risks. This includes KYC protocols, transaction monitoring systems, record-keeping, and reporting mechanisms.

**Appointment of AML Officer:** Appoint a qualified AML Compliance Officer.

**Training:** Ensure staff are adequately trained on AML/CFT policies and procedures.

**Ongoing Compliance:** Continuously monitor compliance, conduct internal audits, and submit required reports (e.g., suspicious transaction reports, periodic compliance reports) to the authorities.

**Ley 7786 - Ley sobre Estupefacientes, Sustancias Psicotrópicas, Drogas de Uso no Autorizado, Actividades Conexas, Legitimación de Capitales y Financiamiento al Terrorismo (Law on Narcotics, Psychotropic Substances, Unauthorized Drug Use, Related Activities, Money Laundering and Financing of Terrorism):**

This is the fundamental AML/CFT law in Costa Rica.

**URL:** While direct government links can change, it's typically found on the official legislative information system or legal databases. A reliable source for the consolidated text (though not always the absolute latest official version) is often available from legal firms or parliamentary sites. Search for "Ley 7786 Costa Rica" on the website of the Asamblea Legislativa or La Gaceta (the official gazette).

*Example (may require navigating for the latest consolidated text):* Sistema Costarricense de Información Jurídica (SCIJ) - search for Ley 7786

**Acuerdo SUGEF 13-10 - Reglamento sobre Legitimación de Capitales, Financiamiento al Terrorismo y Financiamiento de la Proliferación de Armas de Destrucción Masiva Aplicable a los Sujetos Obligados por los Artículos 15 y 15 bis de la Ley 7786 (Regulation on Money Laundering, Financing of Terrorism and Financing of the Proliferation of Weapons of Mass Destruction Applicable to Obligated Subjects under Articles 15 and 15 bis of Law 7786):**

This is SUGEF's detailed regulation for implementing AML/CFT for various obligated subjects. It explicitly mentions virtual assets in its risk assessment guidance.

*Example (navigate to Normativa -> Regulaciones):* SUGEF Official Website

*Direct link to Normativa (may change):* SUGEF Normativa – search for "Acuerdo SUGEF 13-10" within the listed regulations.

**Unidad de Inteligencia Financiera (UIF) - Financial Intelligence Unit:**

Responsible for receiving and analyzing suspicious transaction reports. While it doesn't issue licenses, it's a critical part of the AML ecosystem.

**URL:** Banco Central de Costa Rica - UIF

**Expectation of Profits:** Do purchasers have an expectation of generating a return or profit from their investment? This is often the most critical subjective element.

**Security Tokens (STOs/ICOs structured as investments):** These are almost certainly considered securities. If a token represents equity, debt, a right to profit-sharing, or a share in the project's future revenue, it would fall under SUGEVAL's jurisdiction.

**Utility Tokens (with investment characteristics):** This is a grey area. While marketed for accessing a product or service, if they are sold with an explicit or implicit promise of future value appreciation based on the issuer's efforts, or if they are purchased primarily for speculative investment rather than immediate utility, they could be deemed securities. The timing of utility (immediate vs. future promise) and marketing materials are crucial here.

**NFTs (Non-Fungible Tokens) (potentially):** While many NFTs are purely collectibles, if they are fractionalized, or if their sale is packaged as an investment in a collective asset with an expectation of profit generated by a third party's efforts (e.g., an NFT art fund), they could be classified as securities.

**Stablecoins (less likely, but possible):** Purely fiat-backed stablecoins used for payments are generally not seen as securities. However, if a stablecoin offering includes features like interest accrual or yield generation based on active management of underlying assets by the issuer, it could potentially cross into security territory, especially if marketed as an investment product.

**Payment Tokens (e.g., Bitcoin, Ethereum):** Generally, widely distributed and decentralized cryptocurrencies like Bitcoin and Ethereum are unlikely to be classified as securities by SUGEVAL, as they typically do not involve a "common enterprise" or profits derived from a specific issuer's managerial efforts in the same way an ICO token does. The Central Bank of Costa Rica (BCCR) has clarified they are not legal tender.

Issuers must register the offering and the tokens themselves with SUGEVAL.

This requires submitting a detailed prospectus, financial statements, legal opinions, and disclosing all material information about the issuer, the project, and the tokens.

Compliance involves significant costs, time, and ongoing reporting obligations.

**Private Placement:** The most common exemption for startups or smaller offerings. Offers made to a limited number of qualified investors (e.g., institutional investors, sophisticated individuals) or under specific conditions that do not constitute a "public offering" might be exempt from full registration. The exact criteria are defined in Law 7732 and subsequent regulations, often involving restrictions on advertising and the number of offerees/purchasers.

**Other specific exemptions:** Law 7732 also outlines other limited exemptions, such as offers to specific types of financial institutions or small-scale offerings below a certain monetary threshold (though these are often strictly defined).

**Registered Securities:** Secondary trading of registered securities must occur through authorized stock exchanges (e.g., Bolsa Nacional de Valores - BNV) or licensed brokers regulated by SUGEVAL.

**Unregistered/Exempt Securities:** Tokens initially offered under an exemption (e.g., private placement) are subject to transfer restrictions. They typically cannot be freely traded in the public market for a certain period, and subsequent sales may only be permissible to other qualified investors or through specific channels that maintain the private placement nature.

**Unlicensed Platforms:** Any platform facilitating the secondary trading of securities without proper authorization from SUGEVAL would be operating illegally.

Cryptocurrencies are not legal tender in Costa Rica.

Platforms offering crypto investments are not regulated by SUGEVAL or SUGEF (the banking regulator) unless they fall under existing financial laws (e.g., if they are structured as investment funds or security offerings).

Investors are exposed to high risks (volatility, fraud, lack of investor protection) when dealing with unregulated crypto entities.

The nascent nature of the crypto market in CR.

Many projects might choose to structure themselves to fall outside the current securities framework or operate from offshore jurisdictions.

**Ley Reguladora del Mercado de Valores (Law 7732):** The primary legislation governing securities in Costa Rica.

*Official link (usually through the Legislative Assembly's repository):*

Search for "Ley Reguladora del Mercado de Valores, Ley 7732" on the Costa Rican Legislative Assembly's website or official legal databases.

A common public repository for CR laws is `pgrweb.pgr.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?param1=NRTC&nValor1=1&nValor2=28243&nValor3=33475&strTipM=TC` (Note: This specific URL may change, always verify with official sources).

**Superintendencia General de Valores (SUGEVAL) - Official Website:** Provides information on registered entities, regulations, and investor warnings.

Look for "Alertas al Inversionista" or "Comunicados de Prensa" for warnings related to unregulated investments.

**Banco Central de Costa Rica (BCCR) - Official Website:** Has issued statements regarding the status of cryptocurrencies as legal tender.

As of July 2025, the Costa Rican Legislative Assembly approved debate on a specific bill regulating 'criptoactivos' and VASPs, and by 2026 the country is one of the last without mandatory crypto licensing, but searches for 'criptoactivos' or 'monedas virtuales' remain useful for tracking evolving AML and regulatory developments under SUGEF and ICD oversight.

**Proyecto de Ley para Regular las Actividades de Finanzas Descentralizadas (Fintech Bill 23.033):** While not yet law, it represents the ongoing legislative effort.

*Official link through the Legislative Assembly's website:* Search for "Expediente 23033" on `https://www.asamblea.go.cr/`

**Law No. 7786, "Law on Narcotics, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Money Laundering and Financing of Terrorism" (Ley sobre Estupefacientes, Sustancias Psicotrópicas, Drogas de Uso No Autorizado, Actividades Conexas, Legitimación de Capitales y Financiamiento al Terrorismo)**, as amended. This is Costa Rica's foundational AML/CFT law.

**Law No. 10.363, "Law on the Regulation of Virtual Asset Service Providers" (Ley de Regulación de Proveedores de Servicios de Activos Virtuales)**. This law established the legal framework for VASPs, bringing them under Law 7786's AML/CFT scope. However, the operational AML/CFT obligations and registration mandate became enforceable only after SUGEF's implementing regulation (SUGEF 2-2024) came into effect on November 16, 2024.

**Regulations issued by SUGEF:** While Law 10.363 sets the legal framework, the Superintendent General of Financial Entities (SUGEF) is responsible for developing specific regulations. The key implementing regulation, **SUGEF 2-2024 ("Reglamento para la Inscripción y Supervisión de los Proveedores de Servicios de Activos Virtuales")**, was issued and became effective on November 16, 2024. It details registration, CDD, transaction monitoring, STR, and record-keeping requirements for VASPs.

**Identification and Verification of Customer Identity:**

Identification number (e.g., national ID card, passport number)

Contact information (e.g., phone number, email address)

Source of funds/wealth (as part of Enhanced Due Diligence (EDD) for high-risk clients, which may include scrutiny of large transactions as a contributing factor to the risk assessment).

Verification through reliable, independent source documents, data, or information (e.g., government-issued ID, utility bills).

Legal name, legal nature or type of entity (naturaleza jurídica), and proof of incorporation/registration (copia certificada de la personería jurídica).

Registered office address (domicilio o dirección física de la sede social).

Corporate identification number (número de identificación), which in Costa Rica commonly serves as the tax identification number (cédula jurídica / Número de Identificación Tributaria).

Names of directors, partners, and senior management.

Identification of **Beneficial Owners (BOs)**: VASPs must identify and verify the identity of all natural persons who ultimately own or control the legal entity (typically those holding 25% or more of shares or voting rights, or otherwise exercising control).

Nature of business and purpose of the business relationship.

**Purpose and Intended Nature of the Business Relationship:** Understanding why the customer wants to use the VASP's services.

Regularly monitoring transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Keeping customer information, documents, and data up-to-date.

Periodically reviewing the risk categorization of customers.

**Risk-Based Approach (RBA):** VASPs must apply CDD measures on a risk-sensitive basis. This means applying enhanced due diligence (EDD) for higher-risk customers, transactions, or business relationships (e.g., Politically Exposed Persons (PEPs), cross-border correspondent relationships, complex/unusual transactions). Simplified due diligence (SDD) may be applied in specific lower-risk scenarios.

**Trigger:** Any transaction, attempted transaction, or activity where the VASP suspects or has reasonable grounds to suspect that the funds or assets are proceeds of criminal activity (including money laundering) or are related to terrorist financing.

**Reporting Body:** The report must be submitted to the **Unidad de Inteligencia Financiera del Instituto Costarricense sobre Drogas (UIAD)**, which is Costa Rica's FIU.

**No Tipping Off:** VASPs and their employees are prohibited from disclosing to the customer or any third party that an STR has been, or will be, filed.

**Timing:** Reports must be made without delay, typically within a few days of forming the suspicion.

Customer identification data (collected during CDD).

Costa Rica has proposed but not yet enacted a law requiring virtual asset service providers to maintain transaction records; as of early 2026, no specific regulatory obligation for such record-keeping is in force.

Records of suspicious transaction reports filed.

Records of risk assessments, internal policies, and training materials.

**Retention Period:** Records must generally be kept for a minimum of **five (5) years** after the business relationship is terminated or after a transaction is conducted.

**Accessibility:** Records must be readily available and easily retrievable by the supervisory authority and law enforcement upon request.

**Superintendencia General de Entidades Financieras (SUGEF)**

**Register** with SUGEF as an obligated subject for AML/CFT purposes.

**Implement an AML/CFT compliance program** in line with Law N° 7786 (Ley sobre estupefacientes, sustancias psicotrópicas, drogas de uso no autorizado, actividades conexas, legitimación de capitales y financiamiento al terrorismo).

**Conduct Know Your Customer (KYC)** and Customer Due Diligence (CDD) procedures.

**Monitor transactions** for suspicious activity.

**Report suspicious transactions (STRs)** to SUGEF's Financial Intelligence Unit (FIU).

**Maintain adequate records** for the required periods.

**Ley N° 7786:** (Law on Narcotics, Psychotropic Substances, Unauthorized Drugs, Related Activities, Money Laundering, and Terrorism Financing). This is the foundational AML/CFT law.

**SUGEF Resolution SUGEF 15-22 (January 2022):** This resolution, while not directly linkable as a public document through a simple URL on SUGEF's site, is widely acknowledged in legal analyses for designating VASPs as obligated subjects. It aligns Costa Rica with FATF Recommendation 15 regarding virtual assets.

General SUGEF Normative Section (where such resolutions are published): https://www.sugef.fi.cr/normativa/

There are ongoing discussions within the Central Bank and SUGEF regarding the broader financial innovation landscape.

Like many jurisdictions, Costa Rica is monitoring international developments, particularly the recommendations from the Financial Action Task Force (FATF) and regulatory approaches in more advanced markets (e.g., MiCA in the EU, or frameworks in the US).

Ensure full compliance with **Law N° 7786** and **SUGEF Resolution SUGEF 15-22** regarding AML/CFT obligations.

Implement robust internal controls and best practices for security, asset segregation, and risk management, even if not explicitly mandated by current regulation.

Monitor legislative developments closely, as the regulatory landscape for digital assets is dynamic.

Seek legal counsel specializing in Costa Rican financial and cryptocurrency law.

**Law No. 7786: "Ley sobre Estupefacientes, Sustancias Psicotrópicas, Drogas de Uso no Autorizado, Actividades Conexas, Legitimación de Capitales y Financiamiento al Terrorismo" (Law on Narcotics, Psychotropic Substances, Unauthorized Drugs, Related Activities, Money Laundering, and Financing of Terrorism).** This law, and its subsequent reforms, establishes the general AML/CFT obligations for supervised entities.

**Legal Reference:** **Ley No. 7786** (available through the official legislative information system, e.g., Procuraduría General de la República - Sistema Costarricense de Información Jurídica): http://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?param1=NXT&nValor1=1&nValor2=39485&nValor3=44622&nValor4=59762&strTipM=TC

**SUGEF (Superintendencia General de Entidades Financieras):** The General Superintendency of Financial Entities (SUGEF) is the primary regulator for financial institutions and is responsible for overseeing AML/CFT compliance. While Costa Rica has been cautious in fully regulating crypto as traditional financial assets, SUGEF has clarified that entities involved in certain crypto-related activities (especially those meeting the FATF definition of a VASP) fall under its purview concerning AML/CFT obligations. SUGEF issues regulations and circulars, such as:

**Circular SUGEF 15-2019 (Reglamento sobre la gestión de riesgo de legitimación de capitales, financiamiento al terrorismo y financiamiento de la proliferación de armas de destrucción masiva):** This regulation outlines the risk management framework for money laundering, terrorism financing, and proliferation financing. It applies to all supervised entities and implicitly requires adherence to international sanctions lists as part of a robust risk assessment and due diligence process.

**Legal Reference:** Check SUGEF's official website for current regulations: https://www.sugef.fi.cr/ (Look for "Normativa" or "Reglamentos").

**Customer Due Diligence (CDD):** Identifying and verifying the identity of all customers, including beneficial owners.

**Sanctions Screening:** Screening all new and existing customers (individuals and entities), beneficial owners, and, where appropriate, transaction counterparties against relevant international sanctions lists (UN, OFAC, EU). This should be an ongoing process.

**Risk-Based Approach:** Implementing a risk-based approach to identify and mitigate the risks associated with sanctions evasion, particularly given the anonymity potential of some virtual assets.

**Reporting:** Reporting suspicious transactions, including those potentially related to sanctions violations or attempts to evade sanctions, to the Financial Intelligence Unit (UIF) of Costa Rica, which operates under the Costa Rican Institute on Drugs (ICD).

**Sanctioned Jurisdictions:** Countries or regions subject to comprehensive sanctions (e.g., Cuba, Iran, North Korea, Syria under certain regimes).

**Designated Individuals/Entities:** Individuals or entities located anywhere in the world who are on international sanctions lists (UN, OFAC, EU).

**Administrative Penalties:** SUGEF can impose fines on supervised entities for non-compliance with AML/CFT regulations. These fines can be substantial and are calculated based on the severity and recurrence of the violation.

Individuals involved in money laundering or terrorism financing activities, or those who knowingly facilitate such activities by failing to comply with their obligations, can face imprisonment under Law 7786, and Bill 22.837 has extended this penalties framework to specifically include VASP-related violations.

**Law 7786** specifies penalties for money laundering (legitimación de capitales) and financing of terrorism, which can range from **10 to 20 years of imprisonment**.

Consult Law No. 7786 as extended by Bill 22.837 for specific penalty clauses, particularly for Virtual Asset Service Provider (VASP)-related violations.

**e-money/Payment Tokens:** Stablecoins are **not automatically classified as e-money or payment tokens** under Costa Rican law. For something to be considered e-money, it typically needs to be issued by a regulated financial entity (like a bank or licensed e-money issuer) under the framework of the **Ley de Sistemas de Pagos (Law No. 8454)**. Most stablecoins, particularly those issued by non-financial entities, would not meet these criteria. If a stablecoin were issued by a financial institution and widely accepted for payment with appropriate guarantees, it *might* be deemed e-money, but this would be an exceptional case.

**Ley de Sistemas de Pagos (Law No. 8454):** https://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?param1=NXT&nValor1=1&nValor2=54378&nValor3=58849&strTipM=TC (Spanish)

**Securities:** A stablecoin *could potentially* be classified as a security if its structure and offering meet the definition of a security under the **Ley Reguladora del Mercado de Valores (Securities Market Law, Law No. 7732)**. This would depend on factors such as whether it represents an investment contract, grants rights to profits, or is marketed as an investment opportunity. The **Superintendencia General de Valores (SUGEVAL)**, the securities regulator, would be responsible for this determination on a case-by-case basis.

**Ley Reguladora del Mercado de Valores (Law No. 7732):** https://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?param1=NXT&nValor1=1&nValor2=28340&nValor3=33621&strTipM=TC (Spanish)

**Virtual Assets for AML/CFT Purposes:** The most consistent classification applied to stablecoins (and other cryptocurrencies) is as "virtual assets" for the purposes of Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) regulations.

**No specific reserve requirements exist for stablecoins themselves.** Since there is no dedicated stablecoin regulation, there are no legal mandates for issuers to hold specific reserves.

If a stablecoin were to be somehow classified as e-money issued by a regulated financial institution, then that institution would be subject to the existing capital, liquidity, and operational requirements for e-money issuers, which implicitly require sufficient backing and responsible management of funds.

Similarly, if classified as a security, general financial disclosure and capital requirements for securities issuers might apply, but not specific "reserve" mandates in the stablecoin sense.

**No specific stablecoin issuer license exists.**

However, entities providing services related to stablecoins (e.g., exchange, transfer, custody, or conversion between stablecoins and fiat currency) are likely to be classified as **Virtual Asset Service Providers (VASPs)**. As VASPs, they fall under the **Ley sobre estupefacientes, sustancias psicotrópicas, drogas de uso no autorizado, actividades conexas, legitimación de capitales y financiamiento al terrorismo (Law No. 7786)**.

Under Law No. 7786 and its implementing regulations (**Reglamento SUGEF 1-20**), VASPs are considered "obligated subjects" (sujetos obligados) and must:

Register with the **Superintendencia General de Entidades Financieras (SUGEF)**.

Implement robust AML/CFT policies and procedures (e.g., Know Your Customer - KYC, transaction monitoring, suspicious activity reporting).

Comply with international AML/CFT standards set by the Financial Action Task Force (FATF).

**Ley No. 7786 (AML/CFT Law):** https://www.pgrweb.go.cr/scij/Busqueda/Normativa/Normas/nrm_texto_completo.aspx?param1=NXT&nValor1=1&nValor2=24346&nValor3=33190&strTipM=TC (Spanish)

**Reglamento SUGEF 1-20 (Normativa para la Gestión de Riesgo de Legitimación de Capitales y Financiamiento al Terrorismo para los sujetos obligados por la Ley 7786):** This regulation is accessible via the SUGEF website under "Normativa" -> "Disposiciones Generales." https://www.sugef.fi.cr/normativa/disposiciones_generales/Paginas/default.aspx (Spanish)

**No specific legal guarantee for redemption rights for stablecoin holders** in Costa Rica's current legal framework.

Redemption rights would primarily be governed by the terms and conditions (private contract) established by the stablecoin issuer. Any failure to honor redemption would fall under general contract law.

If a stablecoin were ever to be formally regulated as e-money, then specific redemption rights for e-money holders (e.g., redemption at par value at any time) would likely apply as per existing e-money regulations.

**There are no specific rules or regulations for algorithmic stablecoins** in Costa Rica.

The general lack of specific stablecoin regulation means that algorithmic stablecoins face the same ambiguous legal status as other stablecoins, with the primary regulatory concern being AML/CFT compliance for related VASP activities. The BCCR would likely view these with even greater caution due to their inherent volatility and complexity.

The **Banco Central de Costa Rica (BCCR) has been actively studying the feasibility and implications of issuing its own Central Bank Digital Currency (CBDC)**.

In various reports and public statements, the BCCR has acknowledged the potential benefits (e.g., financial inclusion, payment efficiency, monetary policy effectiveness) and challenges (e.g., financial stability, cybersecurity) of a CBDC.

Currently, there is **no direct regulatory interaction between a potential CBDC and private stablecoins**, as a CBDC is still in the exploration phase and private stablecoins lack a specific regulatory framework.

The BCCR's exploration of a CBDC is driven by its mandate to ensure financial stability and efficient payment systems. A CBDC could potentially offer a safer and more stable digital alternative to private stablecoins, which the BCCR views as carrying significant risks for users. Therefore, a CBDC might be seen as a long-term strategy to address some of the issues that private stablecoins currently present.

**Reference:** The BCCR regularly publishes economic reports and studies that may touch upon digital currencies and CBDCs. It's recommended to check their official publications section: https://www.bccr.fi.cr/ (Spanish)

**Requirement:** As a member state of the United Nations, Costa Rica is legally bound to implement sanctions resolutions adopted by the UN Security Council under Chapter VII of the UN Charter. This includes asset freezes, travel bans, arms embargoes, and other targeted measures against designated individuals, entities, and countries.

**Compliance for VASPs:** VASPs in Costa Rica must screen their customers and transactions against the UN Security Council's Consolidated Sanctions List. This is a fundamental requirement of AML/CFT programs.

**UN Security Council Resolutions:** Various resolutions, e.g., those establishing sanctions regimes for specific countries (DPRK, Iran, etc.) or terrorist groups (Al-Qaida, ISIS).

**UN Consolidated Sanctions List:** https://www.un.org/securitycouncil/content/un-sc-consolidated-list

**Requirement:** While OFAC sanctions are primarily extra-territorial U.S. law, their global reach means that any VASP or financial entity operating internationally, interacting with U.S. persons, or using U.S. dollar infrastructure, must consider OFAC compliance. Failure to do so can lead to severe penalties, even for non-U.S. entities.

**Compliance for VASPs:** VASPs in Costa Rica that have direct or indirect dealings with the U.S. financial system, U.S. persons, or U.S.-origin technology must screen customers and transactions against OFAC's Specially Designated Nationals (SDN) and Blocked Persons List, as well as other OFAC sanctions lists.

**OFAC Sanctions Programs and Country Information:** https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-country-information

**Requirement:** Similar to OFAC, EU sanctions (e.g., asset freezes, restrictions on financial transactions) have a significant impact globally, especially for entities dealing with EU persons, entities, or operating within the EU's sphere of influence.

**Compliance for VASPs:** VASPs in Costa Rica conducting business with EU customers or partners should implement screening against the EU's consolidated list of sanctions.

**Regulator Name:** Superintendencia General de Entidades Financieras (SUGEF)

**Entity Targeted:** General public, regulated financial institutions, and implicitly, anyone operating with virtual assets in Costa Rica.

**Violation Type:** N/A (This is a regulatory clarification, not an enforcement action for a violation). However, financial institutions are warned about the risks of dealing with unregulated entities or engaging in unregulated activities.

**Date:** Ongoing, with several communiques. Key ones include:

**September 2021:** SUGEF Circular SGF-0036-2021 reiterates that virtual assets are not legal tender and are not regulated by SUGEF unless they fall under existing regulated activities.

**January 2022:** SUGEF continues to issue warnings regarding the risks of virtual assets.

**Outcome:** SUGEF maintains that virtual assets are not regulated financial products or services under its supervision. Financial institutions are advised to exercise extreme caution when dealing with virtual assets and to ensure compliance with existing AML/CFT regulations if handling any related transactions. This means that if a bank facilitates transactions involving crypto, it must still comply with its existing AML obligations.

SUGEF Official Website (communiques are often published here, though direct links to specific circulars can be hard to maintain as websites update): https://www.sugef.fi.cr/

News reports often cover SUGEF's stance. For instance, see articles from reputable Costa Rican financial news outlets discussing these circulars: https://www.elfinancierocr.com/ (You would typically search for "SUGEF criptomonedas" on such sites for specific articles around the mentioned dates).

**Regulator Name:** Banco Central de Costa Rica (BCCR)

**Entity Targeted:** General public, financial system.

**Violation Type:** N/A (Warnings about risks, not enforcement).

**Date:** Ongoing, with official statements reinforcing the stance.

**November 2021:** BCCR reiterates that cryptocurrencies are not legal tender in Costa Rica and highlights risks associated with their use.

**2022-2023:** Continued statements about the speculative nature and lack of regulatory backing.

**Outcome:** Heightened public awareness of the risks (volatility, fraud, lack of consumer protection, no state backing) associated with virtual assets. The BCCR clarifies it does not regulate or guarantee them.

The BCCR official website is https://www.bccr.fi.cr/, but press releases and statements are now located at specific subdirectories such as https://www.bccr.fi.cr/comunicacion-y-prensa/comunicados-de-prensa and https://www.bccr.fi.cr/publicaciones/pol%C3%ADtica-monetaria-e-inflaci%C3%B3n/comunicados-de-pol%C3%ADtica-monetaria.

News articles covering BCCR's position: Search "BCCR criptomonedas" on major Costa Rican news sites.

**Regulator/Agency Name:** Organismo de Investigación Judicial (OIJ - Judicial Investigation Organization), Ministerio Público (Public Ministry/Prosecutor's Office)

**Entity Targeted:** Individuals or informal groups involved in illicit schemes. (Specific company names are rare unless it's a front).

**Violation Type:** Money laundering, fraud, illicit enrichment, drug trafficking, or other predicate offenses *using* cryptocurrencies.

**Penalty Amount:** Varies significantly based on court rulings; often involves prison sentences and forfeiture of assets (including crypto). Specific penalty amounts tied to a crypto-related financial fine from a *regulator* are not publicly available for these cases.

**Date:** Ongoing. Cases are investigated and arrests made periodically. It is challenging to provide a *single, specific significant case* with all details and public URLs, as these are criminal investigations.

**Example (illustrative, not specific to last 3 years due to public data scarcity):** News reports over the years have documented OIJ investigations into cybercrime and fraud where victims sent crypto to scammers, or where crypto was used to move illicit funds.

**Outcome:** Arrests, ongoing investigations, legal proceedings, and potential convictions for individuals involved in criminal activities. Assets, including cryptocurrencies, may be seized.

OIJ Press Releases (if available and public): https://www.oij.go.cr/

Costa Rican News Outlets (e.g., La Nación, Teletica, CRHoy) will report on significant arrests related to fraud or cybercrime:

**Regulatory Clarification & Warnings:** SUGEF and BCCR consistently inform the public and financial institutions that cryptocurrencies are unregulated and carry significant risks.

**Application of Existing Laws:** Any "enforcement" involving cryptocurrencies falls under existing anti-money laundering, fraud, or other criminal statutes, handled by traditional law enforcement agencies like the OIJ and the Public Ministry, targeting individuals involved in illicit activities.