New AML Law Ties Costa Rica Crypto Sector to FATF Compliance
Costa Rica will begin enforcing Ley 10961 in September 2026, requiring virtual asset service providers to register with financial regulator SUGEF under anti-money laundering rules aligned with international standards.
Ley 10961 amends Costa Rica's 1998 anti-money laundering statute to bring exchanges, custodians, payment processors, and token issuers under SUGEF supervision for the first time. Registered providers must verify customer identities, screen transactions against United Nations Security Council sanctions lists, and file suspicious transaction reports with the Financial Intelligence Unit at the Instituto Costarricense sobre Drogas. SUGEF will keep a central registry of inscribed providers, which the law allows the regulator to publish.
The law addresses a gap regulators had flagged: Costa Rica's digital asset sector previously operated without dedicated anti-money laundering rules, the kind of weakness the Financial Action Task Force weighs when it decides whether to place a country on its grey list. A grey list designation typically leads correspondent banks abroad to restrict dealings with banks in that country, which can disrupt the cross-border transfers Costa Rican businesses rely on. By extending controls aligned with FATF standards to virtual asset service providers, Ley 10961 closes that gap.
Once the law takes effect, SUGEF-regulated banks will be barred from maintaining commercial relationships with unregistered providers. SUGEF can fine companies two to 100 base salaries for failing to register and 5 percent to 50 percent of the transaction amount for unreported transfers of $10,000 or more.
"A SUGEF registration is becoming the reference point institutional compliance teams check before they open a due diligence file," said Aaron Glauberman, Managing Partner and Head of Regulatory Research at LegalBison. "Once a company is in the registry, a bank or a fund can point to that when it explains, to its own regulator, why it agreed to work with them." LegalBison provides fractional anti-money laundering officers and registration support to companies preparing for the September deadline.
LegalBison provides legal and compliance services to Web3 and financial technology companies. The firm handles corporate structuring and token design. The firm also provides outsourced compliance leadership. The staff monitors international frameworks and regional laws to help companies operate within legal boundaries.