--- title: "Costa Rica (CR) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/costa-rica/ source_html: /jurisdictions/costa-rica/index.html description: "Financial integrity intelligence for Costa Rica (CR): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: e0afb89f8b83e2be6c72680ef839aff085a9a284a7c2cf16bc5c6e26535b6701 generator: "fe-fleet/md-twin@1.0" --- # Costa Rica (CR) — Financial-Integrity Intelligence · Sentinel 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 covered 8 of 8 Sources 137 Role actions 8 Horizon <90d 3 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Increasing Enablement vs enforcement: Mixed 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). More GAFILAT'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 Costa Rica has opened a public consultation on amending Acuerdo Sugef 13-19, the instrument that would bring virtual-asset service providers directly under the AML customer-identification and suspicious-activity-reporting regime supervised by Sugef. The proposal was published through La Gaceta Alcance N.164/N.187 on 5 October 2026 by the National Council for Supervision of the Financial System (CONASSIF), and press reporting as of 23-24 October 2026 confirms the consultation remains open. As drafted, virtual-asset operators would need to identify their clients at a reported threshold around US$1,000, attribute wallet addresses to verified clients, retain records of their operations, and report suspicious transactions to Sugef and the financial intelligence unit. This is a structural development rather than an enforcement incident: Costa Rica currently has no operative AML customer-identification or reporting rule for virtual-asset operators beyond the bare registration duty created by Law 10961, so the amendment would be the first substantive supervisory layer placed on the sector. Read full brief #### Lead Signal Costa Rica has opened a public consultation on amending Acuerdo Sugef 13-19, the instrument that would bring virtual-asset service providers directly under the AML customer-identification and suspicious-activity-reporting regime supervised by Sugef. The proposal was published through La Gaceta Alcance N.164/N.187 on 5 October 2026 by the National Council for Supervision of the Financial System (CONASSIF), and press reporting as of 23-24 October 2026 confirms the consultation remains open. As drafted, virtual-asset operators would need to identify their clients at a reported threshold around US$1,000, attribute wallet addresses to verified clients, retain records of their operations, and report suspicious transactions to Sugef and the financial intelligence unit. This is a structural development rather than an enforcement incident: Costa Rica currently has no operative AML customer-identification or reporting rule for virtual-asset operators beyond the bare registration duty created by Law 10961, so the amendment would be the first substantive supervisory layer placed on the sector. Commentary accompanying the proposal is notably explicit that registration under the amended framework would not constitute an operating authorization or license, a distinction that matters for how the market and counterparties read compliance signals once any registration regime takes effect. The consultation's closing date and final text were not reachable through primary-tier sources this pass, so the standing position rests on secondary press and commentary rather than the official gazette or regulator portal directly. #### Other Developments No other Costa Rica-specific material met this cycle's bar. Sanctions exposure, beneficial-ownership and corporate-transparency architecture, enabler-jurisdiction dynamics, conflict-finance nexus, compliance-technology posture, the broader AML/CTF regime, and commercial-activity findings for Costa Rica were all assessed and found stable, with no new material movement to report this cycle. The published standing positions for those areas remain in force unchanged. #### Cross-Monitor Connections The Sugef 13-19 amendment sits at the intersection of financial-integrity supervision and digital-asset market structure: a jurisdiction moving a previously unsupervised VASP population into an identification-and-reporting perimeter is the kind of structural change that affects how illicit-finance typologies routed through virtual-asset rails get surfaced, independent of whether any single enforcement action follows. Where other monitors track commodity flows, state-capture dynamics, or information operations that obscure illicit money movement, a jurisdiction newly imposing customer-identification duties on VASPs changes the friction such flows encounter if they transit Costa Rican-registered virtual-asset operators. No cross-jurisdictional linkage beyond Costa Rica itself was evidenced this cycle, and the connections above are offered as structural orientation rather than an asserted finding of cross-border flow. #### Outlook The consultation is expected to progress toward a final text within the fourth quarter of 2026, as scheduled, though the record does not establish whether the comment period has closed or whether CONASSIF has set a definitive adoption date, so this should be read as the proposal standing at the consultation stage rather than as enacted law. Should the amendment be adopted substantially as drafted, Costa Rica-registered virtual-asset operators would move from a bare registration duty to a full identification, record-keeping and suspicious-activity-reporting obligation, which is a meaningful compliance-architecture shift for that sector specifically. Subsequent reporting should be watched for the gazetted final text, the effective date, and any penalty provisions attached to non-compliance, none of which were available in the material reviewed this cycle. Earlier periodic briefs (7) 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Costa Rica has opened a public consultation on amending Acuerdo Sugef 13-19, the instrument that would bring virtual-asset service providers directly under the AML customer-identification and suspicious-activity-reporting regime supervised by Sugef. The proposal was published through La Gaceta Alcance N.164/N.187 on 5 October 2026 by the National Council for Supervision of the Financial System (CONASSIF), and press reporting as of 23-24 October 2026 confirms the consultation remains open. As drafted, virtual-asset operators would need to identify their clients at a reported threshold around US$1,000, attribute wallet addresses to verified clients, retain records of their operations, and report suspicious transactions to Sugef and the financial intelligence unit. This is a structural development rather than an enforcement incident: Costa Rica currently has no operative AML customer-identification or reporting rule for virtual-asset operators beyond the bare registration duty created by Law 10961, so the amendment would be the first substantive supervisory layer placed on the sector. Commentary accompanying the proposal is notably explicit that registration under the amended framework would not constitute an operating authorization or license, a distinction that matters for how the market and counterparties read compliance signals once any registration regime takes effect. The consultation's closing date and final text were not reachable through primary-tier sources this pass, so the standing position rests on secondary press and commentary rather than the official gazette or regulator portal directly. #### Other Developments No other Costa Rica-specific material met the bar. Sanctions exposure, beneficial-ownership and corporate-transparency architecture, enabler-jurisdiction dynamics, conflict-finance nexus, compliance-technology posture, the broader AML/CTF regime, and commercial-activity findings for Costa Rica were all assessed and found stable, with no new material movement to report. The published standing positions for those areas remain in force unchanged. #### Cross-Monitor Connections The Sugef 13-19 amendment sits at the intersection of financial-integrity supervision and digital-asset market structure: a jurisdiction moving a previously unsupervised VASP population into an identification-and-reporting perimeter is the kind of structural change that affects how illicit-finance typologies routed through virtual-asset rails get surfaced, independent of whether any single enforcement action follows. Where other monitors track commodity flows, state-capture dynamics, or information operations that obscure illicit money movement, a jurisdiction newly imposing customer-identification duties on VASPs changes the friction such flows encounter if they transit Costa Rican-registered virtual-asset operators. No cross-jurisdictional linkage beyond Costa Rica itself was evidenced, and the connections above are offered as structural orientation rather than an asserted finding of cross-border flow. #### Outlook The consultation is expected to progress toward a final text within the fourth quarter of 2026, as scheduled, though the record does not establish whether the comment period has closed or whether CONASSIF has set a definitive adoption date, so this should be read as the proposal standing at the consultation stage rather than as enacted law. Should the amendment be adopted substantially as drafted, Costa Rica-registered virtual-asset operators would move from a bare registration duty to a full identification, record-keeping and suspicious-activity-reporting obligation, which is a meaningful compliance-architecture shift for that sector specifically. Subsequent reporting should be watched for the gazetted final text, the effective date, and any penalty provisions attached to non-compliance, none of which were available in the material reviewed. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Costa Rica has moved to close a long-flagged gap in its anti-money-laundering architecture for virtual asset service providers. Following the June 2026 enactment of Law 10961, which added Article 15 quater to the base AML statute Law 7786 and placed virtual asset service providers under the supervision of the national financial supervisor SUGEF, the National Council for Financial System Supervision opened a public consultation in early October 2026 on a draft amendment to Acuerdo SUGEF 13-19. The draft would operationalise the new registration requirement with risk-based customer due diligence, new-product and new-technology risk assessment, and suspicious-transaction reporting duties for registered virtual asset providers. The statutory registration requirement itself is well evidenced in the official gazette, but the substantive content of the draft amendment currently rests on secondary press reporting rather than the consultation text itself, so the shape of the final rule should be treated as probable rather than settled. This is best read as a remediation step rather than a new vulnerability. Costa Rica's virtual-asset sector had sat for years in a supervisory vacuum, a posture long associated with a non-compliant rating against the Financial Action Task Force's Recommendation 15 on new technologies. The consultation does not create a licensing regime, and commentary accompanying the statutory change has been explicit that registration with SUGEF is not an authorisation or permit to operate, but it does create the first formal AML perimeter around virtual asset activity in the jurisdiction. #### Other Developments A long-standing casino obligation provides useful context for the new virtual-asset perimeter. Costa Rican casinos, whether physical or internet-based, have been designated AML-obliged entities under Article 15 bis of Law 7786 since 2017, and have been supervised under the same Acuerdo SUGEF 13-19 framework since December 2020. This is not a development of the current cycle but a standing feature of the regime, confirmed directly from SUGEF's own training materials. It is worth noting because it demonstrates that SUGEF already has an operating model for bringing non-bank, high-cash-intensity obliged entities into its supervisory perimeter, a model the virtual-asset consultation appears to be extending to a new sector rather than inventing from scratch. Costa Rica's broader standing with the regional mutual-evaluation process remains unchanged but is approaching a new test. The jurisdiction is not on the Financial Action Task Force's list of countries with strategic deficiencies, and no grey-listing or black-listing development occurred. However, the Latin American Financial Action Task Force body has listed a possible onsite visit for its Fifth Round Mutual Evaluation of Costa Rica for 1 November 2026, with a possible plenary discussion around July 2027. This evaluation would reassess the country's technical compliance and effectiveness against the full set of international AML/CTF recommendations, several of which remained below full compliance at the 2015 Fourth Round evaluation. #### Cross-Monitor Connections The virtual-asset registration and consultation activity sits squarely at the intersection of financial-crime supervision and digital-asset market structure: the same Article 15 quater registration requirement and the same draft SUGEF 13-19 amendment are material to institutions tracking Costa Rica's crypto licensing and market-access posture, since the AML registration gateway is, at present, the only formal regulatory foothold a virtual asset provider has in the jurisdiction. The absence of a parallel licensing or consumer-protection regime means the AML perimeter is currently doing double duty as the primary point of regulatory contact for the sector, a dynamic worth tracking jointly rather than treating the AML and market-structure threads as independent. #### Outlook The SUGEF 13-19 consultation was still open as of late October 2026, with no confirmed closing date or adoption timeline independently verified; secondary reporting has referenced a short consultation window and unresolved questions on compliance-officer appointment criteria for registered providers. Whether the amendment is adopted substantially as drafted, and whether it is adopted before the possible November 2026 GAFILAT onsite visit, are both open questions worth monitoring together, since a credible operationalisation of the Article 15 quater registration regime ahead of the onsite visit would be a relevant data point for the Fifth Round evaluation's assessment of Recommendation 15 compliance. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Costa Rica's financial-integrity architecture moved on two fronts in October 2026. CONASSIF approved Acuerdo 2055-2026 unanimously and in firm vote on 5 October 2026, at its session 2055-2026, publishing the measure in Gazette Supplement No. 138 on 14 October 2026. The agreement amends the securities-offering regulation to require issuers to disclose, in prospectuses, any shareholder, direct, indirect or linked through an economic group, holding 10 percent or more of the issuer. Investment managers and administrators face new fit-and-proper screening covering experience, background and international sanctions and watch-list exposure. The measure took effect on publication, with a six-month compliance window for already-registered issuers, and it reads as a deliberate beneficial-ownership tightening in the securities-market segment of the AML perimeter. Alongside this, the Virtual Asset Service Provider registration duty created under Ley 10961, in force since 19 September 2026, remains in an implementation gap. As of 2 October 2026 CONASSIF had not published, or even opened consultation on, the implementing regulation that would give the registration duty an actual form, platform or window. Costa Rica therefore has a binding legal obligation with no operative mechanism behind it, a structural condition rather than a single incident. #### Other Developments Fintech governance under discussion. The Banco Central de Costa Rica board, at its ordinary session of 16 September 2026, considered consolidating governance of the fintech sector under CONASSIF rather than retaining direct administration at the central bank. No instrument has been adopted and the matter remains at the deliberation stage, but if carried through it would centralise payments, fintech and crypto AML supervisory architecture under a single body. Standing sanctions exposure. The U.S. Treasury's Office of Foreign Assets Control designated five Costa Rican nationals and five Costa Rica-based entities in connection with narcotics trafficking and money laundering. This action predates the current reporting window and is carried forward unchanged as a standing fact rather than a new development. FATF and GAFILAT standing. Costa Rica remains outside both the FATF call-for-action list and the increased-monitoring list, and continues under GAFILAT's enhanced follow-up process against its 2024 mutual evaluation ratings of 17 Compliant and 20 Largely Compliant. No change in this status occurred this cycle. Commercial activity, thin signal. Aggregator data describes a Costa Rican fintech sector of 123 companies, 28 of them funded, with cumulative venture funding of 70.4 million dollars and three acquisitions recorded to date. No single dated transaction within this window was independently verified against a primary source, so this remains background texture rather than a dated finding. #### Cross-Monitor Connections The CONASSIF beneficial-ownership tightening intersects directly with corporate-transparency questions that the World Payments Monitor and the data-protection monitor track from their own angles, particularly where investment-firm ownership disclosure touches entities also active in payments or data processing. The VASP registration implementation gap is the same underlying fact the crypto monitor examines from a licensing-architecture perspective and the World Payments Monitor notes via its Sentinel feed; here the emphasis is the AML-supervisory consequence of a statute in force without an operative registration mechanism. The prospective BCCR-to-CONASSIF governance transfer, if it proceeds, would be a structural supervisory-architecture event relevant to any monitor tracking fintech or crypto oversight in Costa Rica. #### Outlook The CONASSIF implementing regulation for VASP registration is expected in Q4 2026, though this estimate carries quarter-level uncertainty and industry has no confirmed registration platform, threshold schedule, or fee structure to work from as scheduled. Whether the regulation closes the current gap before year end will determine whether Costa Rica's VASP AML perimeter becomes operationally real or remains a paper obligation into 2027. The BCCR governance question remains at the discussion stage, and its resolution either way will shape how fintech and crypto supervision in Costa Rica is organised going forward. The securities-market beneficial-ownership tightening under Acuerdo 2055-2026 is now in force, with the six-month compliance window for registered issuers the next milestone to watch. 4 Oct 2026 · fim-2026-10-04 #### 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. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Costa Rica has closed a longstanding FATF Recommendation 15 gap by formally bringing virtual asset service providers within AML/CFT obligated-entity status. New Article 15 quater of Law No. 7786, added by Legislative Decree No. 10961, was unanimously approved in the Legislative Assembly on 25 and 27 May 2026. VASPs must now register with SUGEF for AML/CFT supervisory purposes, though this registration is explicitly stated not to constitute an operating licence. This is an architecture-level shift: the country has extended its AML/CFT perimeter to a sector it had not previously reached, without simultaneously building a substantive licensing regime for that sector. #### Other Developments GAFILAT follow-up concludes with three upgrades. Costa Rica's enhanced follow-up process for its fourth-round mutual evaluation concluded with upgrades on Recommendation 17 from partially compliant to compliant, Recommendation 22 from partially compliant to largely compliant, and Recommendation 28 from non-compliant to largely compliant. This is a technical-compliance improvement across customer due diligence for financial institutions, DNFBP coverage, and regulation and supervision of DNFBPs respectively, reducing the count of identified deficiencies against Costa Rica's mutual evaluation. Comprehensive AML bill reported to pass third reading. A single legal-commentary source reports that Bill 6593, described as a comprehensive AML/CFT law, passed its third reading on 14 April 2026. This claim has not been independently corroborated, and the bill's scope and its relationship to the existing Law 7786 framework remain unverified this cycle; it is treated as an uncertain development pending confirmation against a primary legislative record. #### Cross-Monitor Connections The VASP AML/CFT registration reform is directly relevant to the crypto monitor's licensing coverage of Costa Rica, which is tracking the same Article 15 quater reform from a licensing-perimeter perspective; that monitor's crypto_licensing module is the appropriate venue for analysis of what the registration requirement does and does not confer in terms of operating authorisation. The world-payments monitor's AML/CFT and financial-crime module for this jurisdiction is supplied from this same D7 and D1 material and should be read as consistent with the account given here. #### Outlook The near-term question is whether Costa Rica's next GAFILAT or FATF assessment cycle will register the VASP AML/CFT reform as a further closure of outstanding technical-compliance gaps, building on the R.17, R.22 and R.28 upgrades already achieved. Separately, confirmation of Bill 6593's actual content, scope and legislative status against a primary source remains an open item; until that confirmation arrives, its relationship to the existing Law 7786 AML/CFT framework, and whether it represents a distinct overhaul or a related but separate instrument, cannot be stated with confidence. 14 Sep 2026 · fim-2026-08-21 #### Lead Signal Costa Rica registered two rounds of unilateral U.S. Treasury sanctions action this cycle, both assessed at High confidence from Tier 1 sourcing. In August 2025, OFAC designated Celso Manuel Gamboa Sanchez, a former Vice Minister of Public Security, together with his law firm and a soccer club, under Executive Order 14059 for facilitating narcotics-trafficking-linked money laundering. In January 2026, a second action designated five Costa Rican nationals and five Costa Rica-based entities connected to the Luis Manuel Picado Grijalba cocaine-trafficking network under the same authority. Both actions carry a severity_preliminary rating of CRITICAL in the interpreter record, reflecting the direct implication of a former senior security official and a coordinated multi-entity network rather than an isolated individual designation. No corresponding European Union Council or UK OFSI designation against either set of targets has been identified, a divergence consistent with a broader pattern of US-led autonomous listing against Costa Rica-linked narcotics money laundering that the interpreter record flags as worth sustained tracking rather than a one-off enforcement episode. #### Other Developments Professional and commercial vehicles as laundering fronts. The January 2026 OFAC action named a law firm and a sports club as facilitation vehicles, alongside several Costa Rica-based entities used for storage and transport within the cocaine-trafficking network. Because the designated facilitators include a law firm — a category of professional gatekeeper whose services carry an inherent presumption of legitimacy — the finding illustrates the architecture-over-incident principle directly: the exposure is structural, professional-services capture, rather than confined to the individual transaction chain the designation formally targets. This is consistent with an enabler-jurisdiction characterization assessed at Assessed confidence. VASP registration reform closes a FATF gap. Costa Rica's Legislative Assembly unanimously approved Amendment No. 25.340 to Law No. 7786 on 27 May 2026, inserting a new Article 15 quater that brings virtual-asset service providers into the AML/CFT obligated-entity perimeter via mandatory SUGEF registration; the amendment was published as Legislative Decree No. 10961 in La Gaceta on 19 June 2026. The interpreter record treats this as closing a documented FATF Recommendation 15 gap on virtual-asset activity, though it is explicitly a registration-for-supervision regime rather than an operating licence, and the corroborating sourcing this cycle is Tier 3 professional-services commentary rather than a retrieved primary La Gaceta text. The reform's practical reach is still unsettled: SUGEF implementing regulations for VASP registration are expected within roughly three months of the gazette publication, but their issuance has not yet been confirmed, leaving open how customer due diligence, record-keeping and suspicious-transaction-reporting mechanics will actually operate in practice. Comprehensive AML statute progressing, single-sourced. A Comprehensive AML Law, Bill 6593, is reported to have passed its third reading in the Legislative Assembly on 14 April 2026, replacing decree-level provisions dating to 2001. This claim carries only Low confidence this cycle, resting on a single Tier 3 source with no corroborating primary legislative record retrieved. Separately, Costa Rica is confirmed, at Assessed confidence from a Tier 1 FATF/GAFILAT source, to remain outside the FATF grey list while continuing in GAFILAT's enhanced follow-up process stemming from its 2015 Mutual Evaluation, with follow-up reporting through 2024. #### Cross-Monitor Connections The VASP registration reform is the clearest cross-monitor node this cycle. The same SUGEF registration requirement that closes the FATF R.15 gap for this monitor is the substrate for the Crypto Monitor's own crypto_licensing and cross_border_transfer findings, which read the identical Article 15 quater / Decree 10961 reform as a supervisory-perimeter expansion rather than an operating-licence regime. Neither monitor's registration record yet extends to a confirmed operating-licence framework for the underlying crypto-asset activity itself, a gap both this monitor's D5 tracker and the Crypto Monitor's own crypto_licensing module independently flag as the more consequential open question going into the next cycle. The World Payments Monitor's fintech-sector tracking, which records Costa Rica's growing domestic payments and lending fintech population, sits adjacent to this same reform: an expanding fintech and virtual-asset sector operating without a licensing framework, now newly subject to AML/CFT registration, is the structural condition this monitor's D5 and D7 findings and World Payments' product-innovation tracking are both, independently, describing from their respective lenses. #### Outlook The immediate items to watch are whether SUGEF issues the implementing regulations for VASP registration expected within roughly three months of the 19 June 2026 gazette publication, and whether Bill 6593's reported third-reading passage is corroborated by a primary legislative record next cycle. Continued unilateral OFAC designation activity against Costa Rica-linked narcotics-money-laundering targets, absent any EU or UK parallel action, is a sanctions-regime divergence pattern worth sustained tracking rather than a single-cycle anomaly. A third OFAC action against a Costa Rica-linked target without a parallel EU Council or OFSI listing would harden this observation from an assessed pattern into a more confidently structural finding. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal Costa Rica closed a long-flagged gap in its anti-money-laundering architecture this cycle. Legislative Decree No. 10961, amending Article 15 quater of Law 7786 and published in La Gaceta on 19 June 2026, brings virtual-asset service providers into a mandatory SUGEF registration regime for the first time (fim-2026-W32-001). The decree is explicit that SUGEF registration is not an operating licence, but it is the mechanism by which Costa Rica closes the FATF Recommendation 15 gap identified in its mutual-evaluation follow-up process. The architecture matters more than any single enforcement action here: Costa Rica has moved from having no dedicated AML supervisor for virtual-asset activity to having a registration gateway, even though the implementing detail, the CONASSIF regulation that will specify KYC, travel-rule, and suspicious-transaction-reporting infrastructure, remains pending, expected in the third quarter of 2026 (fim-2026-W32-006). Many smaller virtual-asset service providers domiciled in Costa Rica have operated to date with no formal AML supervisor at all, and the gap between the registration mandate now in force and the implementing regulation still pending is itself a supervisory window worth tracking. #### Other Developments Sustained unilateral sanctions pressure. The United States Treasury Office of Foreign Assets Control designated a cocaine-trafficking and money-laundering network centred on Costa Rica on 22 January 2026, naming five individuals and five Costa Rica-based entities, with the Moin seaport identified as a transshipment and laundering node amid rising violence in the Limon region (fim-2026-W32-002, fim-2026-W32-007). This followed an August 2025 designation of Celso Manuel Gamboa Sanchez, a former Vice Minister of Public Security, together with his law firm and a football club, for selling counter-narcotics intelligence to trafficking targets his ministry was meant to be pursuing (fim-2026-W32-003). Two rounds of unilateral OFAC action inside twelve months, against a former senior security official and a large trafficking network alike, is a sustained cadence rather than an isolated event, and no corresponding EU Council or OFSI designation has been identified alongside it. The pairing of a trafficking-network designation with a former security official designation illustrates how sanctions-architecture and state-capture risk can co-locate within a single enabler corridor. Extradition-bar repeal reduces enabler function, unevenly. Ley N.10730, the 2025 reform to Article 32 of the Constitucion Politica, removed the constitutional prohibition on extraditing Costa Rican nationals in narco-trafficking and terrorism cases. Approximately twenty nationals have been the subject of extradition requests since, and the first transfer, Gamboa himself, was completed in March 2026 (fim-2026-W32-004). This materially reduces the historic function of Costa Rica as a safe haven for laundering-linked nationals. It sits alongside a more static picture at the professional-services layer: the Fourth Round enhanced follow-up of GAFILAT upgraded the rating of Costa Rica on Recommendation 17 to Compliant and on Recommendations 22 and 28 to Largely Compliant in February 2024, but continues to flag customer-due-diligence gaps in the notary, legal, and accounting channels used for company formation, ahead of the Fifth Round evaluation (fim-2026-W32-005, fim-2026-W32-008). The enabler-jurisdiction picture is therefore one of improvement at the state level and persistence of weakness at the gatekeeper level. #### Cross-Monitor Connections The Gamboa designation is a state-capture signal as much as a sanctions one: a former Vice Minister of Public Security monetising counter-narcotics intelligence sits squarely in the territory the World Democracy Monitor tracks as institutional compromise, and financial-integrity and governance-integrity readings of the same underlying fact should be read together rather than separately. The VASP registration regime also intersects directly with payments-monitor coverage of Costa Rica crypto-asset and stablecoin-settlement infrastructure: a de facto banking-access precondition for unregistered virtual-asset service providers is simultaneously an AML-architecture finding and a market-access finding, and the two monitors are tracking the same instrument from adjacent angles. #### Outlook The decisive item for the next cycle is the CONASSIF implementing regulation for Article 15 quater, expected in the third quarter of 2026; its content will determine whether the new VASP perimeter of Costa Rica closes the FATF R.15 gap in substance or only in form. The Fifth Round GAFILAT evaluation, not yet scheduled with precision, will test whether the persistent DNFBP customer-due-diligence weakness has been addressed or remains the residual enabler-jurisdiction risk it has been through the Fourth Round follow-up. Continued OFAC designation activity against Costa Rica-linked networks, absent so far any parallel EU or UK action, remains the clearest near-term signal of where sanctions-architecture risk concentrates. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion Costa Rica this cycle offers a clean illustration of the F2 three-level analysis, scheme, enabling architecture, strategic consequence, applied to a single jurisdiction. At the scheme level, the Office of Foreign Assets Control designated, under Executive Order 14059, a Costa Rican narcotics-trafficking network and an affiliated law firm, Bufete Celso Gamboa y Asociados, in August 2025, and separately the Picado Grijalba trafficking network together with associated Costa Rican front entities including a fishing association, a beauty salon and real-estate corporations, in January 2026. Both actions target the counter-narcotics program rather than a jurisdiction-wide sanctions regime, consistent with the targeted-designation approach OFAC has applied to Costa Rica. Continue reading At the architecture level, the recurrence of these designations against domestic front companies indicates that individual sanctions actions are exposing, rather than dismantling, a durable laundering infrastructure built on Costa Rica low-barrier corporate incorporation regime and its non-public beneficial-ownership registry. Naming one set of entities does not appear to alter the conditions that allowed those entities to be formed and used in the first instance, which is the analytical distinction between an incident and an architecture. At the strategic-consequence level, the European Commission December 2025 Delegated Regulation update to the EU high-risk third-country list, which added Russia, Bolivia and the British Virgin Islands, again did not add Costa Rica, sustaining a divergence between US targeted-designation practice and EU jurisdiction-wide risk listing. This divergence most plausibly reflects differing sanctions philosophies rather than a substantive disagreement between Washington and Brussels on the underlying risk level Costa Rica presents, since the same narcotics-driven exposure evidenced by the OFAC designations has not been judged by the European Commission to meet the jurisdiction-wide listing threshold. A further structural point concerns what is absent. No Costa Rica-flagged dark-fleet, shipping, or technology-procurement corridor has been identified in connection with Russian sanctions evasion this cycle. Costa Rica illicit-finance exposure in the review window is overwhelmingly narcotics-driven rather than sanctions-evasion-driven in the Russia-specific sense that dominates sanctions-architecture analysis elsewhere. This absence is itself a signal under the enablement doctrine applied across this monitor, it indicates that Costa Rica functions in this period principally as a counter-narcotics sanctions target rather than as a node in the broader Russian sanctions-evasion architecture tracked elsewhere in this monitor. The practical consequence for institutions operating across both the US and EU regulatory perimeters is compliance friction rather than compliance conflict, obliged entities screening against the OFAC SDN list will encounter Costa Rica-linked designations that do not correspond to any enhanced due diligence trigger under the EU high-risk third-country mechanism, requiring firms to maintain a Costa Rica risk posture calibrated to targeted-entity screening rather than jurisdiction-wide enhanced due diligence. #### Outlook The next material test of this divergence pattern is the European Commission next Article 9 high-risk third-country list update cycle, expected in the fourth quarter of 2026 following the October 2026 FATF plenary, which could either add Costa Rica for the first time or continue the exclusion pattern observed in the December 2025 update. Separately, the next annual US State Department International Narcotics Control Strategy Report Volume II cycle, expected in the first quarter of 2027, will indicate whether the accumulation of OFAC designations and the port-based trade-based money-laundering exposure documented this cycle shift Costa Rica classification as a jurisdiction of money-laundering concern, a change that would recalibrate correspondent-banking risk appetite toward Costa Rica among institutions that key their country-risk models to the INCSR classification. Judgment: No CR-specific sanctions-evasion development identified this cycle. Uncertain #### Beneficial Ownership and Corporate Transparency Costa Rica sits outside the European Union AML Package direct perimeter, and the developments most directly relevant to Costa Rica own regulatory exposure this cycle are domestic and regional rather than EU-originated. The most consequential is the confirmation, via the GAFILAT February 2024 enhanced follow-up, that notary, lawyer and accountant regulation in Costa Rica does not explicitly cover company-formation contribution activity under Recommendation 22, even as Costa Rica technical compliance was upgraded on Recommendation 17 to Compliant and on Recommendations 22 and 28 to Largely Compliant. This unresolved gatekeeping gap sits directly upstream of the front-company laundering scheme the Office of Foreign Assets Control exposed through its January 2026 designation of the Picado Grijalba network, which registered a fishing association, a beauty salon and real-estate corporations as nominally unrelated vehicles to receive, layer and disburse narcotics proceeds. Continue reading The second domestically relevant development is the status of Costa Rica own beneficial-ownership registry, the RTBF, established under Decree 41040-H pursuant to Law 7786. The RTBF is a mandatory but non-public registry, administered with cross-checks against tax and financial-institution records, and its practical effectiveness at defeating exactly the kind of shell-company layering exploited in the Picado Grijalba scheme has not been independently tested by any enforcement or evaluation event this cycle. This is a structural judgment drawn from a primary UNCAC review rather than a new development, but it remains the single most significant latent beneficial-ownership-opacity vulnerability Costa Rica carries into its next mutual evaluation. Globally, the EU AML Package sets the structural direction against which beneficial-ownership regimes worldwide are increasingly measured, but it is not the primary subject matter for a non-EEA jurisdiction such as Costa Rica. That package now comprises three distinct instruments: the AML Regulation, directly applicable across Member States and known as the AMLR, the sixth AML Directive, transposed individually by each Member State, and the AMLA Regulation, which establishes the Anti-Money Laundering Authority and defines its direct and indirect supervisory perimeter. Together these instruments shift supervision of high-risk cross-border obliged entities away from purely national authorities toward a hybrid EU-level regime, with the Anti-Money Laundering Authority beginning direct supervision of a first cohort of high-risk cross-border obliged entities as that regime matures. This is durable structural backdrop rather than a Costa Rica-specific development, since the AMLR, sixth AML Directive and AMLA Regulation perimeter is EU and European Economic Area Member State-specific and does not extend to third countries such as Costa Rica absent an EU high-risk third-country listing, which Costa Rica currently lacks. For Costa Rica, the directly relevant transparency question remains domestic, whether the RTBF registry and the DNFBP gatekeeping gap will withstand the effectiveness testing GAFILAT is expected to apply in the Fifth Round Mutual Evaluation. Costa Rica remains confirmed absent from both the October 2025 and February 2026 FATF Jurisdictions Under Increased Monitoring lists, having concluded its Fourth Round enhanced follow-up in February 2024 with the technical-compliance upgrades described above. This absence from the grey list, read alongside the untested registry and the unresolved DNFBP gap, illustrates a jurisdiction whose formal technical-compliance rating has improved while the practical effectiveness of its beneficial-ownership architecture remains unverified. #### Outlook The determinative near-term event for Costa Rica beneficial-ownership architecture is the GAFILAT Fifth Round Mutual Evaluation, with onsite timing not yet fixed but indicative Plenary discussion around mid-2027. Unlike the 2024 follow-up, which re-rated technical compliance, the Fifth Round is expected to test effectiveness, whether the RTBF registry and DNFBP supervision actually defeat shell-company layering in practice, directly against the front-company architecture the OFAC designations exposed this cycle. A negative effectiveness finding at that evaluation would represent the first substantive corroboration that the gaps identified in 2024 have produced real-world laundering outcomes rather than remaining theoretical. Judgment: No CR-specific beneficial-ownership development identified this cycle. Uncertain #### Enabler Jurisdictions and Professional Facilitators Costa Rica this cycle illustrates the F3 enabler-jurisdiction filter across two distinct but related tracks, physical trade-based laundering infrastructure and narco-political penetration of state institutions. On the trade side, cocaine originating in Colombia is being trans-shipped through Costa Rica Caribbean ports, principally Moin and Limon, and concealed within containerised banana and pineapple exports using gancho ciego and gancho perdido concealment methods. This is corroborated by a 70 million dollar cocaine seizure inside a Costa Rica-origin pineapple shipment intercepted in Spain in late 2025, and by a primary FATF Free Trade Zone money-laundering-vulnerabilities report alongside investigative reporting describing Costa Rica as an emergent cocaine hub. Costa Rica additionally sits within a documented regional banana route running from Brazil and Ecuador through Costa Rica to Europe, which exploits the established, low-suspicion profile of multinational fruit-export supply chains, compounded by the GAFILAT-identified gap in DNFBP coverage of company-formation contribution activity under Recommendation 22. Continue reading This is a systemic capacity question rather than a simple enforcement gap, Costa Rica free-trade-zone and port infrastructure was built to enable a legitimate export-led growth model, and that same infrastructure, combined with relatively light port and customs scrutiny, is now structurally exploited for trans-shipment concealment. Individual seizures and designations expose the scheme without altering the underlying capacity deficit that makes the route attractive. On the narco-political track, Costa Rica judicial police arrested former Security Minister and Supreme Court Justice Celso Gamboa Sanchez in June 2025, pending extradition to the United States on a Drug Enforcement Administration request for international drug trafficking. This illustrates penetration of narco-linked networks into senior state institutions extending well beyond low-level facilitators. Separately, in September 2025, the Legislative Assembly narrowly failed, by a vote of 34 to 21, short of the required two-thirds threshold, to strip President Chaves of immunity over an alleged influence-peddling investigation, illustrating a structural constraint on anti-corruption enforcement reaching the apex of the state, distinct from but related to the Gamboa case in what it reveals about institutional capacity to hold senior office-holders accountable. A further, more thinly evidenced facilitator-network signal concerns cross-border bank ownership. A fugitive suspect in the domestic Madre Patria fraud case was recorded on wiretap describing a family arrangement to acquire an ownership representation in a Mexican bank shortly before a relative was appointed deputy director general of that bank and a group he led became its majority investor. This rests on a single tier-two investigative source based on wiretap allegations and has not been independently corroborated by a regulatory or prosecutorial source this cycle, and is carried at an assessed rather than high confidence level accordingly. #### Outlook The enabler-jurisdiction picture for Costa Rica is likely to be shaped over the coming cycles by two distinct tracks moving on different timelines, the GAFILAT Fifth Round evaluation, which will test whether the DNFBP gatekeeping gap and free-trade-zone exposure have been addressed at a structural level, and the domestic political and judicial process around the Gamboa extradition and any renewed effort to test President Chaves immunity, which will indicate whether narco-political penetration of senior state institutions can be addressed through existing accountability mechanisms or whether those mechanisms continue to fall short of the thresholds required to act. Judgment: No CR-specific enabler-jurisdiction development identified this cycle. Uncertain Judgment: No CR-specific conflict-finance development identified this cycle. Uncertain #### Crypto / Digital Assets / Financial Innovation The defining development for Costa Rica this cycle is the CONASSIF-initiated consultation on amending Acuerdo Sugef 13-19 to bring virtual-asset service providers under Sugef AML supervision. Published via La Gaceta Alcance N.164/N.187 on 5 October 2026, the draft would require VASPs to identify their clients at a reported threshold near US$1,000, attribute wallet addresses to verified individuals, retain operational records, and report suspicious transactions to Sugef and the financial intelligence unit. Press reporting from 23-24 October 2026 indicates the consultation window remains open. This is an architecture-level finding: Costa Rica's virtual-asset sector currently operates under Law 10961's registration duty alone, with no customer-identification or suspicious-activity-reporting layer attached, so the amendment would mark the jurisdiction's first substantive move toward bringing VASPs inside the standard AML perimeter applied to other obliged entities. Continue reading A detail worth foregrounding for the digital-asset reading of this development is the explicit clarification, carried in commentary around the proposal, that registration under the amended Sugef 13-19 framework would not amount to an operating authorization or license. That distinction separates the AML-supervisory question (whether a VASP must identify clients and report suspicious activity) from the market-access question (whether a VASP is licensed to operate), and it signals that Costa Rica's regulators are building the AML layer first without resolving the broader licensing architecture for virtual-asset business at the same time. For firms and counterparties assessing exposure to Costa Rican virtual-asset operators, this means the near-term change is one of reporting and identification obligations rather than a wholesale shift in market-entry requirements. The gap in the current record is material: no primary-tier source (the official gazette text, a Sugef circular, or the CONASSIF consultation portal itself) was reachable to confirm the closing date of the consultation period or the state of the final text. The standing position therefore rests on secondary press (Diario Extra) and a Substack commentary piece, both useful for establishing that the consultation exists and describing its substantive content, but neither capable of confirming procedural status with the certainty a primary document would provide. This is a reporting posture point, not a doubt about whether the consultation itself occurred. The broader context for reading this development is Costa Rica's general standing on international AML benchmarks, where available assessment material notes compliance or largely-compliant ratings against a majority of the FATF forty recommendations. That baseline suggests the Sugef 13-19 amendment is best understood as closing a specific, identified gap in the virtual-asset segment of an AML framework that is otherwise assessed as reasonably developed, rather than as evidence of a systemic weakness being remedied from a low base. #### Outlook If the amendment proceeds to adoption substantially as drafted, Costa Rica-registered virtual-asset operators would acquire, for the first time, a full customer-identification, record-keeping and suspicious-activity-reporting duty running to Sugef and the financial intelligence unit, converting an administrative registration regime into a supervised AML relationship. The structural significance of this shift lies less in any single reporting threshold and more in the fact that it brings VASPs inside the same supervisory logic already applied to Costa Rica's regulated financial institutions, closing a sector-specific gap rather than introducing a wholly new regulatory concept. The expected timeframe, as reported, points toward the fourth quarter of 2026, though whether the comment period has closed and whether a final adoption date has been set remains unconfirmed in the sources reviewed. Future cycles should watch for the gazetted final text, confirmation of an effective date, and any penalty provisions attached to non-compliance, each of which was absent from the material available this cycle and would materially sharpen the compliance picture once published. Judgment: CR's VASP AML perimeter is in active transition from a bare registration duty (Law 10961) to an operationalised Sugef AML supervisory regime once the Sugef 13-19 consultation closes. Probable #### Compliance Technology and Active Defence SUGEF has not published AI/ML-based transaction-monitoring or perpetual-KYC supervisory guidance comparable to the model-risk-management expectations financial supervisors such as FinCEN have articulated in more developed markets. This is a supervisory-expectation gap rather than an enforcement finding: no Costa Rica-specific compliance-technology failure or active-defence deficiency was identified this cycle, and this domain status is recorded as watch rather than material change. The gap is relevant primarily as forward context for the VASP AML/CFT registration mandate introduced under Legislative Decree No. 10961: the CONASSIF implementing regulation, expected in the third quarter of 2026, is the mechanism through which SUGEF could, if it chooses, incorporate technology-specific supervisory expectations into the newly formalised VASP AML perimeter. Continue reading The broader Costa Rica financial-sector compliance-technology posture, including transaction-monitoring standards applicable to banks and other obliged entities beyond VASPs, was not independently assessed this cycle; the coverage gap reflects a general absence of published SUGEF guidance rather than a substantive negative finding. This domain accordingly carries limited signal this cycle: the observation is an absence, of published guidance, rather than a documented deficiency in existing systems. Absent any Costa Rica-specific enforcement action or active-defence deficiency this cycle, this domain remains appropriately flagged as thin rather than substantively assessed, consistent with the honesty-over-coverage principle applied across this monitor coverage. #### Outlook Whether the CONASSIF implementing regulation for VASP AML/CFT registration incorporates technology-specific supervisory expectations, such as AI/ML transaction-monitoring standards or perpetual-KYC requirements, will be the first concrete test of whether SUGEF intends to close this gap as part of the broader VASP-perimeter build-out, or leave technology-specific supervisory expectations for a later phase. Judgment: No CR-specific RegTech/compliance-technology development identified this cycle. Uncertain #### AML/CTF Regime The clearest AML/CTF signal from Costa Rica this cycle is one of institutional depth rather than legal change: Costa Rican casinos, both physical and internet-based, have been AML-obliged entities under Article 15 bis of Law 7786 since an amendment in 2017, and have operated under the supervisory framework of Acuerdo SUGEF 13-19 since December 2020. This is standing law rather than a development of the current cycle, confirmed directly from SUGEF's own training materials, which reproduce the statute's obliged-activities table naming casinos explicitly. Under that framework, casinos must register with SUGEF and the Financial Intelligence Unit housed at the Costa Rican Drugs Institute, maintain a board-approved AML/CTF and proliferation-financing prevention manual, identify high-stake and frequent players, and report suspicious activity. The reason this standing position matters now is that it supplies the operating template SUGEF appears to be extending to virtual asset service providers through the Acuerdo SUGEF 13-19 amendment currently out for consultation -- the same instrument, the same supervisor, and a broadly similar compliance-architecture logic applied to a new category of non-bank obliged entity. Continue reading At the regime level, Costa Rica's broader standing is stable but approaching a formal test. The jurisdiction remains off the Financial Action Task Force's lists of countries with strategic AML deficiencies, and no grey-listing or black-listing action occurred this cycle. It does, however, remain in enhanced follow-up with the regional Latin American Financial Action Task Force body stemming from its 2015 Fourth Round mutual evaluation, and a possible onsite visit for the Fifth Round evaluation has been listed for 1 November 2026, with a possible plenary discussion around July 2027. That evaluation would reassess Costa Rica's technical compliance and effectiveness across the full set of international recommendations, including Recommendation 15 on new technologies, where the jurisdiction's historical rating has been non-compliant, and Recommendation 22 concerning designated non-financial businesses and professions, a category that includes the casino sector already described above. #### Outlook The proximity of the possible November 2026 onsite visit to the open SUGEF 13-19 virtual-asset consultation creates a natural point of convergence worth tracking: evaluators are likely to look at both the maturity of the casino supervisory model, now six years into operation, and the nascent state of the virtual-asset registration regime, which remains at the consultation stage. Whether the amendment is adopted in time to be presented as an operating control rather than a proposal will have a bearing on how the Recommendation 15 finding is treated in the upcoming evaluation cycle, though the evaluation's own timeline and findings are set independently of the consultation's progress. Judgment: CR's standing AML/CTF regime (Law 7786/10961, Sugef supervision, GAFILAT 2024 follow-up rating Compliant/Largely Compliant on 37 of 40 Recommendations) is unchanged this cycle. Probable Judgment: No CR-specific commercial activity in the financial-integrity market identified this cycle. Uncertain Regulatory horizon Consultation 2026-Q4 · ±quarter ### Draft amendment to Acuerdo Sugef 13-19 (VASP AML supervision) If adopted, VASPs become subject to Sugef standard AML customer-identification, record-keeping and suspicious-activity-reporting regime. [Source](https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/) Adopted 2026-Q4 · ±half_year ### Comprehensive AML Law (Bill 6593) Passage of a single consolidated AML/CFT statute replacing older sectoral decree-level provisions. [Source](https://consortiumlegal.com/en/category/area/fintech/) In Force Pending 2026-Q4 · ±quarter ### VASP AML/CFT registration implementing regulations VASPs move from unregulated status to mandatory SUGEF AML/CFT registration with CDD, STR-to-ICD, and record-keeping obligations. [SUGEF / CONASSIF Source](https://www.zitadelleag.com/news/where-to-register-a-vasp-company-without-licensing-costa-rica-and-panama) Proposed 2027-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. [GAFILAT / FATF Source](https://www.fatf-gafi.org/en/calendars/assessments.html) 4 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Costa Rica has opened consultation on bringing virtual-asset providers under Sugef customer-identification and suspicious-activity-reporting duties. Where an institution deals with Costa Rican virtual-asset counterparties, the proposed Sugef 13-19 amendment would, if adopted, create a new identification and reporting relationship for those counterparties that does not currently exist, changing the due-diligence picture for such exposures once in force. 1 evidence refs Compliance ### A draft amendment to Acuerdo Sugef 13-19 would place Costa Rican virtual-asset operators inside the standard AML customer-identification and reporting perimeter. The policy and control-framework implication is that Costa Rica-based or Costa Rica-exposed VASP relationships currently assessed against a bare registration requirement may need re-assessment once the amendment is adopted, since the compliance baseline for those counterparties would shift materially. 1 evidence refs Legal ### Costa Rica clarifies that Sugef 13-19 registration would not itself constitute a license or operating authorization. The distinction between AML-supervisory registration and a market-access license is a liability-relevant separation: counterparty risk assessments should not treat registration under the amended rule, once adopted, as evidence of licensed operating status. 1 evidence refs Board ### Costa Rica is moving to close a specific gap in its AML framework by bringing virtual-asset providers under Sugef supervision. This is a structural, not an incident-level, development: it indicates the jurisdiction is extending an already reasonably rated AML framework to a previously unsupervised sector, which is relevant to strategic exposure assessments involving Costa Rican digital-asset relationships. 1 evidence refs CTO ### Proposed Sugef 13-19 amendment would require Costa Rican VASPs to attribute wallet addresses to verified clients and retain operational records. If adopted, this introduces specific technical obligations around client-wallet attribution and record retention for any platform or infrastructure handling Costa Rican virtual-asset activity, which is a direct architecture and data-handling implication for affected systems. 1 evidence refs Risk ### Costa Rica's virtual-asset sector is moving from an unsupervised registration regime toward an AML-supervised perimeter. This changes the risk profile of Costa Rica-linked virtual-asset exposure from an unmonitored gap toward a reporting-covered relationship, which is the kind of structural shift that should be reflected in exposure-concentration assessments involving this jurisdiction once the rule is adopted. 1 evidence refs Operations ### A reported identification threshold near US$1,000 and new reporting duties are proposed for Costa Rican virtual-asset operators. Should the amendment be adopted, transaction-monitoring and screening workflows touching Costa Rican VASP counterparties would need to account for a new identification threshold and a suspicious-activity-reporting channel to Sugef and the financial intelligence unit that does not currently apply. 1 evidence refs Audit ### No primary-tier source confirmed the closing date or final text of the Sugef 13-19 consultation this cycle. The evidentiary basis for this development currently rests on secondary press and commentary rather than the official gazette or regulator portal, which is a documented gap in the current audit trail that should be closed once a primary source becomes reachable. 1 evidence refs Scenario sketches ### Illustrative transition from national VASP registration toward a hybrid AML-supervised perimeter Considered as an illustrative structural pattern rather than a prediction, a jurisdiction that moves from a bare market-registration duty for virtual-asset operators toward a full AML identification and reporting perimeter can be expected to surface previously invisible activity within its own reporting channel, while operators seeking to avoid the new perimeter might shift activity toward unregistered or offshore counterparties not reached by the amended rule. This mirrors, at a smaller structural scale, the broader move seen elsewhere from purely national AML supervision toward layered supervisory architectures combining a directly applicable regulation, a transposed directive, and a dedicated supervisory authority. The illustration is offered to orient analysis of how a national VASP AML amendment interacts with cross-border virtual-asset flows, not as an assessment of what Costa Rica will in fact experience. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No CR-specific Russian sanctions-evasion development identified this cycle. T2 · EU AML Package / AMLA no_change CR is not an EEA/EU member; AMLR/6AMLD/AMLA have no direct application to CR. T3 · FATF Grey List no_change CR is not on the FATF grey or black list; 2024 GAFILAT follow-up rated CR Compliant on 17 and Largely Compliant on 20 of 40 Recommendations. T4 · Beneficial-Ownership Register Status no_change No CR-specific BO registry development identified this cycle. T5 · Crypto & Digital-Asset Integrity watch CONASSIF's open consultation on amending Sugef 13-19 to bring VASPs under AML supervision continues; follows Law 10961 and GAFILAT's 2023 Non-Compliant rating on Recommendation 15. T6 · Sanctions Regime Divergence no_change No new CR-specific sanctions designation or divergence item identified this cycle. Registers ### Enforcement actions - 18 Aug 2025 - 22 Jan 2026 - 23 Jun 2025 - 18 Aug 2025 - 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 - 18 Aug 2025 - 22 Jan 2026 - 4 Dec 2025 - 18 Aug 2025 - 22 Jan 2026 - 18 Aug 2025 - 22 Jan 2026 - 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) - CONASSIF implementing regulation for VASP AML/CFT registration under Art. 15 quater, Law 7786 - VASP AML/CFT registration implementing regulations - Comprehensive AML Law (Bill 6593) - VASP AML/CFT registration implementing regulations - Comprehensive AML law (Bill 6593) - CONASSIF implementing regulation for Art. 15 quater (Law 7786) VASP thresholds - GAFILAT 5th-round mutual evaluation of Costa Rica - CONASSIF implementing regulation for VASP registration under Ley 10961 - Draft amendment to Acuerdo Sugef 13-19 (VASP AML supervision) - Proposed amendment to Acuerdo Sugef 13-19 bringing VASPs under Sugef AML supervision - 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 - [COSTA RICA LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/08867878) - [https://home.treasury.gov/news/press-releases/sb0227](https://home.treasury.gov/news/press-releases/sb0227) - [https://ofac.treasury.gov/recent-actions/20250818](https://ofac.treasury.gov/recent-actions/20250818) - [https://home.treasury.gov/news/press-releases/sb0369](https://home.treasury.gov/news/press-releases/sb0369) - [https://ofac.treasury.gov/recent-actions/20260122](https://ofac.treasury.gov/recent-actions/20260122) - [https://www.fatf-gafi.org/en/countries/detail/Costa-Rica.html](https://www.fatf-gafi.org/en/countries/detail/Costa-Rica.html) - [https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Costa-Rica-2024.html](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Costa-Rica-2024.html) - [https://www.step.org/industry-news/costa-rican-government-introduces-vasp-framework](https://www.step.org/industry-news/costa-rican-government-introduces-vasp-framework) - [https://consortiumlegal.com/en/category/area/fintech/](https://consortiumlegal.com/en/category/area/fintech/) - [https://www.zitadelleag.com/news/where-to-register-a-vasp-company-without-licensing-costa-rica-and-panama](https://www.zitadelleag.com/news/where-to-register-a-vasp-company-without-licensing-costa-rica-and-panama) - [https://www.cubaliteraria.com/crypto-requirements-in-costa-rica-2026-what-virtual-asset-businesses-must-know-about-aml-cft-and-rtbf/](https://www.cubaliteraria.com/crypto-requirements-in-costa-rica-2026-what-virtual-asset-businesses-must-know-about-aml-cft-and-rtbf/) - [https://www.elfinancierocr.com/economia-y-politica/plataformas-de-criptomonedas-en-costa-rica-deberan/AF6VZ7DNN5DGBDGKJHFH5NEAXY/story/](https://www.elfinancierocr.com/economia-y-politica/plataformas-de-criptomonedas-en-costa-rica-deberan/AF6VZ7DNN5DGBDGKJHFH5NEAXY/story/) - [https://www.step.org/industry-news/only-minor-deficiencies-remain-costa-ricas-aml-measures-says-fatf](https://www.step.org/industry-news/only-minor-deficiencies-remain-costa-ricas-aml-measures-says-fatf) - [https://www.imprentanacional.go.cr/pub/2026/06/19/ALCA78_19_06_2026.pdf](https://www.imprentanacional.go.cr/pub/2026/06/19/ALCA78_19_06_2026.pdf) - [https://bufetedecostarica.com/ley-proveedores-de-servicios-de-activos-virtuales-en-costa-rica-10961/](https://bufetedecostarica.com/ley-proveedores-de-servicios-de-activos-virtuales-en-costa-rica-10961/) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://consortiumlegal.com/en/2026/06/24/vasp-regulation-costa-rica/](https://consortiumlegal.com/en/2026/06/24/vasp-regulation-costa-rica/) - [https://legalbison.com/crypto-license/costa-rica/](https://legalbison.com/crypto-license/costa-rica/) - [https://www.riotimesonline.com/costa-rica-illicit-trade-organised-crime-2026](https://www.riotimesonline.com/costa-rica-illicit-trade-organised-crime-2026) - [El Financiero (CR)](https://www.elfinancierocr.com/finanzas/conassif-refuerza-controles-sobre-duenos-y/NSBWV5NG2NCILESBCRLITERNRY/story/) - [Bufete de Costa Rica](https://bufetedecostarica.com/ley-proveedores-de-servicios-de-activos-virtuales-en-costa-rica-10961/) - [Corporacion GC](https://www.corporaciongc.com/articulos/costa-rica-vasp-registration-sugef) - [U.S. Department of the Treasury](https://home.treasury.gov/news/press-releases/sb0369) - [KnowYourCountry](https://www.knowyourcountry.com/country-aml-intelligence/country/costa-rica/) - [El Financiero (CR)](https://www.elfinancierocr.com/finanzas/banco-central-considera-trasladar-al-conassif-la/2QBOT2I3YJFBTJRSG7TXTVCDOU/story/) - [Tracxn](https://tracxn.com/d/explore/fintech-startups-in-costa-rica/__MBOfHLy3hsNwnlfba68s0d6NKVlcWnfcNigHu6_-hVg) - [https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/](https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/) - [https://josemoras.substack.com/p/la-sugef-empieza-a-vigilar-el-negocio](https://josemoras.substack.com/p/la-sugef-empieza-a-vigilar-el-negocio) - [https://www.fatf-gafi.org/en/countries/global-network/financial-action-task-force-of-latin-america--gafilat-.html](https://www.fatf-gafi.org/en/countries/global-network/financial-action-task-force-of-latin-america--gafilat-.html) - [https://www.easlatam.com/news/hoteles-y-casinos-que-son-sujetos-obligados-ante-sugef-e-icd](https://www.easlatam.com/news/hoteles-y-casinos-que-son-sujetos-obligados-ante-sugef-e-icd) - [https://www.sugef.fi.cr/sujetos%20inscritos%20ley%207786%20-%20(%20apnfd)/informacion%20apnfd/Capacitacion%20Sugef%2011-18%20del%2018-03-2025.pdf](https://www.sugef.fi.cr/sujetos%20inscritos%20ley%207786%20-%20(%20apnfd)/informacion%20apnfd/Capacitacion%20Sugef%2011-18%20del%2018-03-2025.pdf) - [Diario Extra](https://www.diarioextra.com/noticia/proveedores-de-activos-virtuales-deberan-reportar-operaciones-sospechosas/) - [José Mora (Substack)](https://josemoras.substack.com/p/la-sugef-empieza-a-vigilar-el-negocio) - [KnowYourCountry](https://www.knowyourcountry.com/country-reports/costa-rica/) - [https://www.knowyourcountry.com/country-reports/costa-rica/](https://www.knowyourcountry.com/country-reports/costa-rica/) - [Costa Rica](https://www.fatf-gafi.org/en/countries/detail/Costa-Rica.html) - [Costa Rica continues to strengthen measures against money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Costa-Rica-2024.html) - [Financial Action Task Force of Latin America (GAFILAT)](https://www.fatf-gafi.org/en/countries/global-network/financial-action-task-force-of-latin-america--gafilat-.html) - [Enhanced Follow-up report and Technical Compliance re-rating of Costa Rica](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-Costa-Rica-2024.pdf.coredownload.pdf) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Jurisdictions under Increased Monitoring - 21 February 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2025.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Costa Rica's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-costa-rica-2015.html) - [Costa Rica's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-Costa-Rica-2023.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [First follow-up report to Costa Rica’s assessment of anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-costa-rica-2016.html) - [International Narcotics Control Strategy Report Volume II Money Laundering](https://syntheticdrugs.unodc.org/uploads/syntheticdrugs/res/library/cybercrime_html/US_International_Narcotics_Control_Strategy_Report_Money_Laundering.pdf) - [Money Laundering vulnerabilities of Free Trade Zones](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/ML%20vulnerabilities%20of%20Free%20Trade%20Zones.pdf) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Counter Narcotics Designations and Designation Removal; Counter Terrorism, Global Magnitsky, and Russia-related Designation Updates | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250818) - [Counter Narcotics Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20231115) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [Counter Narcotics and Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250813) - [Counter Narcotics Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260122) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Directory of Open-Source Registries: Costa Rica](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/costa-rica.html) - [Strategy guidance note on beneficial ownership registries](https://publicadministration.desa.un.org/sites/default/files/cepa-sessions/Strategy%20note%20beneficial%20ownership%20registries%20Oct%202024_0.pdf) - [Catalogue of Research Databases | OCCRP ID](https://id.occrp.org/databases/) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, Sets New Deadlines for Foreign Companies | FinCEN.gov](https://www.fincen.gov/news/news-releases/fincen-removes-beneficial-ownership-reporting-requirements-us-companies-and-us) - [Guidance on Beneficial Ownership and Transparency of Legal Arrangements](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html) - [Beneficial Ownership Information Reporting | FinCEN.gov](https://www.fincen.gov/boi) - [Frequently Asked Questions | FinCEN.gov](https://www.fincen.gov/boi-faqs) - [United Nations CAC/COSP/IRG/II/4/1/Add.11 Conference of the States Parties](https://track.unodc.org/uploads/documents/UNCAC/WorkingGroups/ImplementationReviewGroup/10-14June2024/CAC-COSP-IRG-II-4-1-Add.11/2404059E.pdf) - [CRIMJUST investigative case forum between Costa Rica and Spain promotes cooperation & ensures that drug-related crimes are investigated beyond seizures](https://www.unodc.org/unodc/en/drug-trafficking/crimjust/news/crimjust-investigative-case-forum-between-costa-rica-and-spain-promotes-cooperation-and-ensures-that-drug-related-crimes-are-investigated-beyond-seizures.html) - [Costa Rica Election: Country’s Rise as Drug Hub Fuels Voter Concerns - Bloomberg](https://www.bloomberg.com/news/features/2026-01-30/costa-rica-election-country-s-rise-as-drug-hub-fuels-voter-concerns) - [Costa Rica](https://www.unodc.org/ropan/en/costa-rica.html) - [Report: Costa Rica Now a Cocaine Hub for South America](https://www.occrp.org/en/daily/1773-report-costa-rica-now-a-cocaine-hub-for-south-america) - [2025_4abril_CostaRica_PCCP](https://www.unodc.org/ropan/en/Noticias/2025_4abril_costarica_pccp.html) - [NarcoFiles: The New Criminal Order | OCCRP](https://www.occrp.org/en/project/narcofiles-the-new-criminal-order) - [World Drug Report 2025 - Maps](https://www.unodc.org/unodc/en/data-and-analysis/world-drug-report-2025-maps.html) - [138 GLOBAL REPORT ON TRAFFICKING IN PERSONS Costa Rica Institutional framework](https://www.unodc.org/documents/human-trafficking/Country_profiles/Central_America_Caribbean.pdf) - [Cocaine from South America to the United States](https://www.unodc.org/documents/toc/Reports/TOCTASouthAmerica/English/TOCTA_CACaribb_cocaine_SAmerica_US.pdf) - [Breaking Down Brazil’s New Crypto Framework](https://www.chainalysis.com/blog/brazil-crypto-asset-regulatory-framework-2025/) - [Venezuela Country Guide | Elliptic](https://www.elliptic.co/country-guides/venezuela) - [2026_23enero_costa_rica_ciberdelito](https://www.unodc.org/ropan/en/Noticias/2026_23enero_costa_rica_ciberdelito.html) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [2025 LATAM Crypto Adoption: Latin America Emerges as Crypto Powerhouse](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [The stablecoin compliance playbook for stablecoin issuers and financial institutions](https://www.elliptic.co/blog/stablecoin-compliance-playbook-for-stablecoin-issuers-and-financial-institutions) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [Commission adds Russia to list of high-risk jurisdictions to strengthen international fight against financial crime](https://ec.europa.eu/commission/presscorner/detail/en/ip_25_2910) - [Anti-Money Laundering and Terrorist Financing Directive 4 - Finance](https://finance.ec.europa.eu/regulation-and-supervision/financial-services-legislation/implementing-and-delegated-acts/anti-money-laundering-and-terrorist-financing-directive-4_en) - [16399/25 ECOFIN 1B EN Council of the European Union Brussels, 4 December 2025](https://data.consilium.europa.eu/doc/document/ST-16399-2025-INIT/en/pdf) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [0 │ FIFTH ENHANCED FOLLOW-UP REPORT OF COSTA RICA October 2018](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Fifth-enhanced-follow-up-report-costa-rica.pdf.coredownload.pdf) - [2022 Procedures for the FATF AML/CFT/CPF Mutual Evaluations, Follow-Up and ICRG](https://www.fatf-gafi.org/en/publications/Mutualevaluations/5th-Round-Procedures.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [GAFILAT Mutual Evaluation Report of the Republic of Costa Rica](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Mutual%20Evaluation%20Report%20Costa%20Rica%202015.pdf) - [First follow-up report to Costa Rica’s assessment of anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/fur-costa-rica-2016.html) - [Costa Rica's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/fur-costa-rica-2018.html) - [Costa Rica Wiretaps Raise Questions Over Mexican Bank Takeover Bid | OCCRP](https://www.occrp.org/en/investigation/costa-rica-wiretaps-raise-questions-over-mexican-bank-takeover-bid) - [Costa Rica Arrests Officials, Construction Company Leaders for Graft | OCCRP](https://www.occrp.org/en/news/costa-rica-arrests-officials-construction-company-leaders-for-graft) - [Costa Rican Bill Seeks to Ban Corrupt Construction Companies | OCCRP](https://www.occrp.org/en/daily/14840-costa-rican-bill-seeks-to-ban-corrupt-construction-companies) - [Costa Rica President Chaves Survives Vote to Strip His Immunity - Bloomberg](https://www.bloomberg.com/news/articles/2025-09-23/costa-rica-president-chaves-survives-vote-to-strip-his-immunity) - [The Dictators’ Bank: How Central America’s Main Development Bank Enabled Corruption and Authoritarianism | OCCRP](https://www.occrp.org/en/project/the-dictators-bank/the-dictators-bank-how-central-americas-main-development-bank-enabled-corruption-and-authoritarianism) - [Turkish Journalist Arrested for Allegedly Insulting Erdogan | OCCRP](https://www.occrp.org/en/news/turkish-journalist-arrested-for-allegedly-insulting-erdogan) - [Costa Rica Arrests Ex-Security Minister Wanted in the US for Drug Trafficking | OCCRP](https://www.occrp.org/en/news/costa-rica-arrests-ex-security-minister-wanted-in-the-us-for-drug-trafficking) - [Costa Rica ex-leader Calderon gets five years for corruption | OCCRP](https://www.occrp.org/en/feature/costa-rica-ex-leader-calderon-gets-five-years-for-corruption) - [US bars executives of Costa Rica’s leading newspaper La Nación from entry - ICIJ](https://www.icij.org/news/2026/05/us-bars-executives-of-costa-ricas-leading-newspaper-la-nacion-from-entry/) - [Corruption Threatens Democracies Worldwide, Transparency International Warns | OCCRP](https://www.occrp.org/en/news/corruption-threatens-democracies-worldwide-transparency-international-warns) - [[Withdrawn] Doing business in Costa Rica: Costa Rica trade and export guide - GOV.UK](https://www.gov.uk/government/publications/exporting-to-costa-rica/doing-business-in-costa-rica-costa-rica-trade-and-export-guide) - [Doing business in Costa Rica - European Commission's trade](https://trade.ec.europa.eu/access-to-markets/en/country/doing-business-costa-rica) - [Panamanian Law Firm Is Gatekeeper To Vast Flow of Murky Offshore Secrets - ICIJ](https://www.icij.org/investigations/panama-papers/20160403-mossack-fonseca-offshore-secrets/) - [Department for Business and Trade Costa Rica - GOV.UK](https://www.gov.uk/world/organisations/department-for-business-and-trade-costa-rica) - [Overseas business risk: Costa Rica - GOV.UK](https://www.gov.uk/government/publications/overseas-business-risk-costa-rica/overseas-business-risk-costa-rica) - [A notorious drug kingpin set up shell companies in the British Virgin Islands and Dubai to employ alleged cartel underlings, documents show - ICIJ](https://www.icij.org/news/2024/08/a-notorious-drug-kingpin-set-up-shell-companies-in-the-british-virgin-islands-and-dubai-to-employ-alleged-cartel-underlings-documents-show/) - [COSTA RICA LIMITED overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/11409526) - [COSTA RICA LIMITED more information - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/11409526/more) - [COSTA RICA LTD overview - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/08867878) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Costa-Rica.html) - [GAFILAT / FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-Costa-Rica-2024.pdf.coredownload.pdf) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [FATF](https://www.fatf-gafi.org/en/calendars/assessments.html) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20250818) - [US Treasury OFAC](https://ofac.treasury.gov/recent-actions/20260122) - [European Commission (DG FISMA)](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [UNODC / UNCAC Implementation Review Group](https://track.unodc.org/uploads/documents/UNCAC/WorkingGroups/ImplementationReviewGroup/10-14June2024/CAC-COSP-IRG-II-4-1-Add.11/2404059E.pdf) - [OCCRP](https://www.occrp.org/en/daily/1773-report-costa-rica-now-a-cocaine-hub-for-south-america) - [Bloomberg](https://www.bloomberg.com/news/features/2026-01-30/costa-rica-election-country-s-rise-as-drug-hub-fuels-voter-concerns) - [OCCRP](https://www.occrp.org/en/investigation/costa-rica-wiretaps-raise-questions-over-mexican-bank-takeover-bid) - [OCCRP](https://www.occrp.org/en/news/costa-rica-arrests-ex-security-minister-wanted-in-the-us-for-drug-trafficking) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-09-23/costa-rica-president-chaves-survives-vote-to-strip-his-immunity) - [ICIJ](https://www.icij.org/news/2024/08/a-notorious-drug-kingpin-set-up-shell-companies-in-the-british-virgin-islands-and-dubai-to-employ-alleged-cartel-underlings-documents-show/) - [FATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/ML%20vulnerabilities%20of%20Free%20Trade%20Zones.pdf) Coverage gaps fim-int-2026-07-07-G001: No dedicated Costa Rican VASP/crypt… fim-int-2026-07-07-G001: No dedicated Costa Rican VASP/crypto-asset sector national risk assessment publication was located to corroborate D5 findings. [resolved] fim-int-2026-07-07-G002: RTBF beneficial-ownership registry … fim-int-2026-07-07-G002: RTBF beneficial-ownership registry effectiveness remains untested pending the outcome of the GAFILAT Fifth Round Mutual Evaluation. [resolved] fim-int-2026-07-07-G003: GAFILAT Fifth Round onsite visit ti… fim-int-2026-07-07-G003: GAFILAT Fifth Round onsite visit timing for Costa Rica is not yet fixed, limiting precision on the D2 horizon assessment. [resolved] fim-int-2026-07-07-G004: No live re-pull of a current UK OFS… fim-int-2026-07-07-G004: No live re-pull of a current UK OFSI/HMT advisory was performed this cycle to independently confirm Costa Rica's UK HRTC status, which is currently inferred from EU alignment. [resolved] fim-int-2026-07-07-G005: The alleged Costa Rica-Mexico bank-… fim-int-2026-07-07-G005: The alleged Costa Rica-Mexico bank-stake acquisition (claim fim-2026-W28-011) rests on a single T2 investigative wiretap report with no independent regulatory or prosecutorial corroboration. [resolved] fim-int-2026-08-05-G001: D4 conflict-finance coverage for Co… fim-int-2026-08-05-G001: D4 conflict-finance coverage for Costa Rica was thin this cycle; no dedicated CR-specific war-economy or conflict-mineral nexus search was completed. [resolved] fim-int-2026-08-05-G002: Tier-D jurisdictions (KH, LA, MX, C… fim-int-2026-08-05-G002: Tier-D jurisdictions (KH, LA, MX, CO) were not independently swept this cycle; collection budget was concentrated on Costa Rica. [resolved] fim-int-2026-08-05-G003: No T1 CONASSIF/SUGEF primary text f… fim-int-2026-08-05-G003: No T1 CONASSIF/SUGEF primary text for the implementing regulation was available this cycle; the horizon item relies on secondary legal-advisory sources for procedural detail. [resolved] fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 La Gaceta or SUGEF publication URL was retrieved for Legislative Decree No. 10961 (VASP registration reform); all corroboration this cycle is T3 professional-services commentary. [resolved] fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-21-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Bill 6593's third-reading passage is single-sourced (T3) this cycle and not corroborated against a primary legislative record. [resolved] fim-int-2026-08-21-G003: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-08-21-G003: Tier D jurisdictions (KH, LA, MX, CO) were not actively searched this cycle given the CR-bound scope of this dispatch. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No T1 legislative-gazette text retrieved for Legislative Decree 10961 (VASP AML reform); reliance on T3 domestic press and T4 vendor commentary caps confidence at Probable. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Bill 6593's scope, relationship to Law 7786, and enactment/publication status could not be independently corroborated this cycle; single T3 source only. [resolved] fim-int-2026-09-28-G003: D1, D2, D3, D4 and D6 yielded no CR… fim-int-2026-09-28-G003: D1, D2, D3, D4 and D6 yielded no CR-specific material this cycle; Tier D watch jurisdictions (KH, LA, MX, CO) were not actively re-swept as the pooled union search budget was concentrated on CR. [resolved] fim-int-2026-10-04-G001: CONASSIF implementing regulation fo… fim-int-2026-10-04-G001: CONASSIF implementing regulation for Art. 15 quater (thresholds, scope, exclusions, technical requirements) has not been published as of this cycle; a direct CONASSIF primary source would resolve the operative detail of the registration regime. [resolved] fim-int-2026-10-04-G002: Whether VASPs are formally extended… fim-int-2026-10-04-G002: Whether VASPs are formally extended into the RTBF beneficial-ownership filing regime rests only on secondary commentary; a primary regulatory or statutory source would confirm this. [resolved] fim-int-2026-10-04-G003: No official Ministerio de Hacienda … fim-int-2026-10-04-G003: No official Ministerio de Hacienda primary notice was independently retrieved this cycle for the broader illicit-trade/criminal-financing estimate; a primary Chamber of Commerce or government report would corroborate the figure. [resolved] fim-int-2026-10-04-G004: Tier-D watch jurisdictions (KH, LA,… fim-int-2026-10-04-G004: Tier-D watch jurisdictions (KH, LA, MX, CO) were not covered this cycle due to the operator-bound CR-only scope lock; this is a scope gap, not a finding of no material change in those jurisdictions. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): Primary CONASSIF/Gazette text for Acuerdo 2055-2026 was not independently retrieved this cycle; the finding rests on a single T3 quality-press source. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): D1, D3, D4 and D6 coverage is thin for Costa Rica this cycle; Tier-D fleet-wide elevated collection requirement was out of scope for this single-JID dispatch. [resolved] fim-int-2026-10-25-G001: Tier D jurisdiction coverage (Cambo… fim-int-2026-10-25-G001: Tier D jurisdiction coverage (Cambodia, Laos, Mexico, Colombia) was not actively re-swept this cycle; the pooled research budget was allocated to Costa Rica per the union run's scope. [resolved] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D2'}): D2, D3, D4 and D8 domains were checked for Costa Rica but yielded no qualifying finding this cycle; this is a coverage gap, not a confirmed absence of activity. [resolved] fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): CONASSIF session minutes and the draft SUGEF 13-19 text itself were not directly retrieved this cycle; the amendment's substantive content rests on T2/T3 secondary reporting rather than the primary draft instrument. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): Whether CONASSIF has closed the Sugef 13-19 consultation comment period and published final implementing text was not confirmed this pass. [open] fim-int-2026-11-01-G002: Tier D jurisdiction watch (KH/LA/MX… fim-int-2026-11-01-G002: Tier D jurisdiction watch (KH/LA/MX/CO) was not performed this pass; this run is structurally bound to a single JID (CR) under the Union per-JID dispatch model, which conflicts with FIM's global Tier-D-every-cycle requirement. [open] FIM-GAP-001 (D3): Despite UNODC Container Control Programme … FIM-GAP-001 (D3): 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. FIM-GAP-002 (D2): GAFILAT's 2024 enhanced follow-up found th… FIM-GAP-002 (D2): 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. FIM-GAP-003 (D3): In September 2025 Costa Rica's Legislative… FIM-GAP-003 (D3): 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. FIM-GAP-004 (D5): No dedicated Costa Rican VASP/crypto-asset… FIM-GAP-004 (D5): 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. [[Source 1]](#sec-sources) Probable · 1 source Penalties of 5%-50% of transaction amount, or 2-100 base salaries, for registration/CDD/reporting failures under Art. 15 quater. [[Source 1]](#sec-sources) 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. [[Source 1]](#sec-sources) Probable · 1 source Possible onsite period November 2026 and possible plenary discussion July 2027 under Costa Rica's 5th-round mutual evaluation (2022 Methodology). [[Source 1]](#sec-sources) 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. [[Source 1]](#sec-sources) 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. [[Source 1]](#sec-sources) Uncertain · 1 source Issuers must disclose in prospectuses any shareholder (direct, indirect or via economic group) holding 10% or more; investment managers face experience, background and international-list screening requirements [[Source 1]](#sec-sources) Probable · 1 source BCCR board discussed (16 Sept 2026 session, reported 7 Oct 2026) ceding direct administration of fintech-sector initiatives to CONASSIF [[Source 1]](#sec-sources) Uncertain · 1 source CONASSIF implementing regulation for VASP registration remained unpublished and no consultation opened as of 2 October 2026 [[Source 1]](#sec-sources) Probable · 1 source Outside both FATF call-for-action and increased-monitoring lists; continuing GAFILAT enhanced follow-up on 2024 ratings (17 Compliant/20 Largely Compliant) [[Source 1]](#sec-sources) Probable · 1 source Five Costa Rican nationals and five Costa Rica-based entities designated for narcotics trafficking and money laundering involvement (January 2026, predates window) [[Source 1]](#sec-sources) Probable · 1 source 123 fintech companies, 28 funded, $70.4M cumulative venture funding, 3 acquisitions to date (aggregator data); no single dated in-window transaction independently verified [[Source 1]](#sec-sources) Uncertain · 1 source Draft amendment to Acuerdo SUGEF 13-19 operationalising VASP AML/CFT obligations under Law 10961 Art. 15 quater [[Source 1]](#sec-sources) Probable · 1 source AML-obliged entities under Law 7786 Art. 15 bis since 2017, supervised under Acuerdo SUGEF 13-19 since 2020 [[Source 1]](#sec-sources) Probable · 1 source Fifth Round Mutual Evaluation of Costa Rica, possible onsite period 1 November 2026, possible Plenary discussion around 1 July 2027 [[Source 1]](#sec-sources) Probable · 1 source consultation_open [[Source 1]](#sec-sources) Probable · 1 source Acuerdo Sugef 13-19 (bringing VASPs under Sugef AML supervision for customer identification and suspicious-activity reporting) [[Source 1]](#sec-sources) Probable · 1 source Virtual-asset service providers, as of 2026-09-19, under Law 7786 Article 15 quater, via Sugef registration duty [[Source 1]](#sec-sources) Probable · 1 source not_listed [[Source 1]](#sec-sources) Probable · 1 source