Costa Rica
Retail_Trading_Status
Status Changed
Previous status: Gray-Zone
Reconciled by prioritizing the live analysis as the source of truth, which correctly identifies the status as Allowed-Unregulated based on multiple sources confirming that crypto activities are legal but unregulated. The latest analysis's Gray-Zone classification was incorrect due to overemphasizing banking restrictions as a partial ban, whereas the core activity remains permitted for individuals under general laws.
- Analysis ID
- #848
- Version
- Latest
- Created
- 2025-12-13 07:04
- Run
- c7519a9a...
- History
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- Workflow Stage
- Reconciled
Executive Summary
Costa Rica permits retail trading of cryptocurrencies but lacks a dedicated regulatory framework. The Central Bank of Costa Rica (BCCR) does not recognize cryptocurrencies as legal tender, emphasizing that their use is at the individual's own risk, and prohibits regulated financial entities from offering crypto services. While no specific crypto regulations exist, general AML/CFT laws apply, and the proposed 'Cryptoassets Market Law' (Bill 23.415) is under legislative debate as of 2025. Retail trading is allowed but operates without crypto-specific licenses or oversight.
Key Pillars
- Primary Regulator and Approach: The Banco Central de Costa Rica (BCCR) monitors but does not regulate cryptocurrencies, emphasizing user risk and prohibiting banks from providing custody or exchange services. The Superintendency General of Financial Entities (SUGEF) oversees compliance with general financial regulations, including AML/CFT, and manages a registry for 'obligated subjects' under Law 7786. The Ministry of Finance (Hacienda) treats crypto as a virtual asset subject to taxation.
- Core Compliance Requirements: General Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) regulations apply to crypto transactions. The Financial Intelligence Unit (UIF) requires reporting of suspicious transactions, which may include crypto activities.
- Licensing/Registration: No specific crypto-related licenses or registration requirements exist, though entities may register with SUGEF under general AML laws.
Landmark Laws
- Law on Narcotic Drugs, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Legitimization of Capitals and Financing of Terrorism (Law 7786) (Enacted: 1998-04-30): General AML law requiring 'obligated subjects' to register with SUGEF and report suspicious transactions; applies broadly to financial activities, including potential crypto entities.
- Regulation for Registration and De-registration with SUGEF (Acuerdo SUGEF 11-18) (Enacted: 2018-11-16): Establishes procedures for AML registration under Law 7786; used by some crypto entities in the absence of specific licensing.
- Proposed Cryptoassets Market Law (Bill 23.415) (Introduced: 2022-10-24, Debated: 2025): Aims to regulate crypto asset services and establish a licensing regime, but not enacted as of mid-2025.
Considerations
- Legal Classification: Cryptocurrencies are not legal tender but are treated as private assets or 'quasi-money' usable in private transactions if accepted.
- Tax Treatment: Crypto gains are subject to capital gains tax (15%) for individuals and corporate income tax for professional traders; the Ministry of Finance has issued clarifying rulings.
- Banking Restrictions: The BCCR prohibits regulated financial institutions from offering crypto services, leading to account closures for crypto-related activities, but retail trading remains permitted through alternative means.
- Risks/Concerns: The U.S. Department of State's 2025 INCSR highlights virtual currencies as a money laundering threat due to lack of specific regulations, echoed by Costa Rican authorities.
- Pending Regulation: The regulatory landscape is in flux with Bill 23.415 under discussion, but no comprehensive framework is in place.
Notes
- Historical Context: The BCCR clarified in 2017 and 2018 that cryptocurrencies are not backed by the government and cannot be used on the national payment system.
- Government Approach: Maintains a 'laissez-faire' or 'vigilant tolerance' stance, allowing crypto activities under general laws without restrictive measures.
- Adoption: Crypto use is growing in sectors like tourism and real estate, with some businesses accepting it for payments or salaries.
- Future Plans: Bill 23.415 seeks to formalize regulation but remains pending; until then, companies must operate within existing legal boundaries.
Remaining Uncertainties
- The exact timeline for the final approval and enactment of Bill 23.415.
- Whether the new law will force existing 'registered' entities to re-apply for a full license.
- The extent to which the Central Bank will relax banking restrictions once the new law is passed.
Detailed Explanation
Detailed Explanation
Costa Rica maintains an 'Allowed-Unregulated' status for cryptocurrency, permitting retail trading and use while lacking a dedicated regulatory framework. The Banco Central de Costa Rica (BCCR) is the primary authority monitoring the space, having clarified in 2017 and 2018 that cryptocurrencies are not legal tender, are not backed by the government, and cannot be used on the national payment system. The BCCR emphasizes that their use is at the individual's own risk and explicitly prohibits regulated financial institutions from offering custody, exchange, or other crypto-related services. The Superintendency General of Financial Entities (SUGEF) oversees compliance with general financial regulations, particularly anti-money laundering (AML) and counter-terrorism financing (CFT) obligations under Law 7786, enacted on April 30, 1998. Under this law, entities considered 'obligated subjects' must register with SUGEF, a process detailed in Acuerdo SUGEF 11-18 from November 16, 2018, and report suspicious transactions to the Financial Intelligence Unit (UIF). The Ministry of Finance (Hacienda) treats cryptocurrencies as virtual assets subject to taxation, applying a 15% capital gains tax for individuals and corporate income tax for professional traders.
The regulatory landscape is characterized by a 'laissez-faire' or 'vigilant tolerance' approach, where crypto activities are allowed under existing general laws without restrictive measures. However, this absence of specific regulation is identified as a vulnerability; both Costa Rican authorities and the U.S. Department of State's 2025 International Narcotics Control Strategy Report (INCSR) highlight virtual currencies as a money laundering threat. The government's stance is in flux, with the proposed Cryptoassets Market Law (Bill 23.415), introduced on October 24, 2022 and under legislative debate as of 2025, aiming to establish a formal licensing regime and comprehensive oversight. Until this bill is enacted, companies and individuals operate in a legal gray area where retail trading is permitted, but they must navigate banking restrictions, rely on alternative payment channels, and ensure compliance with broad AML/CFT requirements. Adoption continues to grow in sectors like tourism and real estate, with businesses accepting crypto for payments, despite the lack of crypto-specific licenses or direct oversight.
Summary Points
Costa Rica Cryptocurrency Regulatory Summary
I. Regulatory Status
* Allowed-Unregulated: Retail trading and use of cryptocurrencies are permitted, but there is no dedicated regulatory framework.
* The Central Bank (BCCR) does not recognize cryptocurrencies as legal tender and states their use is at the user's own risk.
* The government maintains a stance of 'laissez-faire' or 'vigilant tolerance', allowing activities under general laws.
II. Key Regulatory Bodies
* Banco Central de Costa Rica (BCCR): Monitors the space, prohibits regulated financial entities from offering crypto services, and has issued warnings about risks.
* Superintendency General of Financial Entities (SUGEF): Oversees compliance with general financial regulations, including AML/CFT, and manages the registry for 'obligated subjects' under Law 7786.
* Financial Intelligence Unit (UIF): Receives reports of suspicious transactions, which may include crypto activities.
* Ministry of Finance (Hacienda): Treats crypto as a virtual asset for taxation purposes and has issued clarifying rulings.
III. Important Legislation
* Law on Narcotic Drugs, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Legitimization of Capitals and Financing of Terrorism (Law 7786) (Enacted: 1998-04-30): The general AML/CFT law that applies broadly to financial activities, including potential crypto entities. It requires registration with SUGEF and suspicious transaction reporting.
* Regulation for Registration and De-registration with SUGEF (Acuerdo SUGEF 11-18) (Enacted: 2018-11-16): Establishes procedures for AML registration under Law 7786; used by some crypto entities in the absence of specific licensing.
* Proposed Cryptoassets Market Law (Bill 23.415) (Introduced: 2022-10-24, Debated: 2025): Aims to regulate crypto asset services and establish a licensing regime, but is not enacted as of mid-2025.
IV. Compliance Requirements
* AML/CFT: General Anti-Money Laundering and Counter-Terrorism Financing regulations under Law 7786 apply to crypto transactions.
* Registration: Entities may need to register as 'obligated subjects' with SUGEF under the general AML framework, but there are no crypto-specific licenses.
* Reporting: Suspicious transaction reports must be filed with the Financial Intelligence Unit (UIF).
* Taxation: Crypto gains are subject to capital gains tax (15%) for individuals and corporate income tax for professional traders.
V. Notable Restrictions or Limitations
* Banking Prohibition: The BCCR prohibits regulated financial institutions (e.g., banks) from offering custody, exchange, or other crypto services, leading to potential account closures for crypto-related activities.
* Legal Tender Status: Cryptocurrencies are not legal tender and cannot be used on the national payment system.
* Money Laundering Risk: Authorities, including in the 2025 U.S. INCSR report, identify the lack of specific regulation as making virtual currencies a money laundering threat.
VI. Recent Developments or Notes
* Pending Regulation: The regulatory landscape is in flux with Bill 23.415 under legislative debate as of 2025. Its passage would significantly change the framework.
* Historical Context: The BCCR issued public clarifications in 2017 and 2018 distancing itself from crypto and warning of risks.
* Adoption: Crypto use is growing in practice, with some businesses in tourism and real estate accepting it for payments or salaries.
* Legal Classification: Cryptocurrencies are treated as private assets or 'quasi-money' usable in private transactions if accepted by the parties.
Full Analysis Report
Full Analysis Report
Report on Retail Trading Status of Cryptocurrencies in Costa Rica
Date of Report: 2025-06-26
Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).
Retail_Trading_Status: Allowed-Unregulated
1. Identified Current Status: Allowed-Unregulated
2. Detailed Narrative Explanation:
Costa Rica permits retail trading of cryptocurrencies, but the activity operates without a dedicated regulatory framework. The Central Bank of Costa Rica (BCCR) has clarified that cryptocurrencies are not legal tender and are not backed by the government, with transactions conducted at the user's own risk. Despite this, private use is allowed, and there are no laws prohibiting individuals from buying, selling, or holding crypto assets.
General financial laws apply to crypto activities. The Superintendency General of Financial Entities (SUGEF) enforces AML/CFT regulations under Law 7786, which may require crypto entities to register as 'obligated subjects' under Acuerdo SUGEF 11-18. However, no crypto-specific licenses exist. The BCCR prohibits regulated financial institutions from offering crypto services, such as custody or exchange, leading to banking restrictions, but retail traders can use offshore platforms or peer-to-peer methods.
Taxation is clarified by the Ministry of Finance: crypto gains are subject to capital gains tax (15%) for individuals and corporate tax for businesses. The proposed Cryptoassets Market Law (Bill 23.415) has been debated in 2025 to create a formal regulatory regime but remains pending. Authorities have expressed concerns about money laundering risks due to the unregulated nature of crypto, as noted in the 2025 INCSR report.
Overall, retail trading is allowed in an unregulated environment, with compliance required under general laws. The status is expected to remain Allowed-Unregulated until specific legislation is enacted.
3. Specific, Relevant Text Excerpts:
- LegalBison (2025-05-05): "Yes, cryptocurrency activities are legal in Costa Rica. In the absence of dedicated regulation, Costa Rica tolerates crypto activities, as long as they comply with all other existing laws and regulations of the country."
- CoinStats (2025-06-24): "Cryptocurrencies are not recognized by the law as legal tender, making them legal for private transactions."
- BCCR Document (2021-08-06): "Although their use is permitted in Costa Rica, those who wish to acquire these assets do so at their own risk... financial entities are not authorized to offer services related to cryptoassets."
- SUGEF Regulation (2018-11-16): "Obligated subjects that carry out activities described in articles 15 and 15 bis of Law 7786 must register."
- The Tico Times (2025-06-04): "Unregulated in Costa Rica, cryptocurrencies like Bitcoin enable anonymous transactions."
4. Direct, Accessible URL Links to Sources:
- LegalBison: https://legalbison.com/crypto-license/costa-rica/
- CoinStats: https://coinstats.app/blog/crypto-regulations-in-costa-rica/
- BCCR: https://www.bccr.fi.cr/publicaciones/DocInvestigacion/Algunas_consideraciones_en_torno_a_ las_monedas_digitales_y_los_criptoactivos.pdf
- SUGEF: https://www.sugef.fi.cr/normativa/normativa_vigente/reglamentos_sugef/Acuerdo%20SUGEF%2011-18.pdf
- The Tico Times: https://ticotimes.net/2025/06/04/money-laundering-in-costa-rica-key-methods-and-challenges
## Report on Retail Trading Status of Cryptocurrencies in Costa Rica **Date of Report:** 2025-06-26 **Topic:** Retail_Trading_Status **Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued). --- ### Retail_Trading_Status: Allowed-Unregulated --- **1. Identified Current Status:** Allowed-Unregulated **2. Detailed Narrative Explanation:** Costa Rica permits retail trading of cryptocurrencies, but the activity operates without a dedicated regulatory framework. The Central Bank of Costa Rica (BCCR) has clarified that cryptocurrencies are not legal tender and are not backed by the government, with transactions conducted at the user's own risk. Despite this, private use is allowed, and there are no laws prohibiting individuals from buying, selling, or holding crypto assets. General financial laws apply to crypto activities. The Superintendency General of Financial Entities (SUGEF) enforces AML/CFT regulations under Law 7786, which may require crypto entities to register as 'obligated subjects' under Acuerdo SUGEF 11-18. However, no crypto-specific licenses exist. The BCCR prohibits regulated financial institutions from offering crypto services, such as custody or exchange, leading to banking restrictions, but retail traders can use offshore platforms or peer-to-peer methods. Taxation is clarified by the Ministry of Finance: crypto gains are subject to capital gains tax (15%) for individuals and corporate tax for businesses. The proposed Cryptoassets Market Law (Bill 23.415) has been debated in 2025 to create a formal regulatory regime but remains pending. Authorities have expressed concerns about money laundering risks due to the unregulated nature of crypto, as noted in the 2025 INCSR report. Overall, retail trading is allowed in an unregulated environment, with compliance required under general laws. The status is expected to remain Allowed-Unregulated until specific legislation is enacted. **3. Specific, Relevant Text Excerpts:** * **LegalBison (2025-05-05):** "Yes, cryptocurrency activities are legal in Costa Rica. In the absence of dedicated regulation, Costa Rica tolerates crypto activities, as long as they comply with all other existing laws and regulations of the country." * **CoinStats (2025-06-24):** "Cryptocurrencies are not recognized by the law as legal tender, making them legal for private transactions." * **BCCR Document (2021-08-06):** "Although their use is permitted in Costa Rica, those who wish to acquire these assets do so at their own risk... financial entities are not authorized to offer services related to cryptoassets." * **SUGEF Regulation (2018-11-16):** "Obligated subjects that carry out activities described in articles 15 and 15 bis of Law 7786 must register." * **The Tico Times (2025-06-04):** "Unregulated in Costa Rica, cryptocurrencies like Bitcoin enable anonymous transactions." **4. Direct, Accessible URL Links to Sources:** * LegalBison: https://legalbison.com/crypto-license/costa-rica/ * CoinStats: https://coinstats.app/blog/crypto-regulations-in-costa-rica/ * BCCR: https://www.bccr.fi.cr/publicaciones/DocInvestigacion/Algunas_consideraciones_en_torno_a_ las_monedas_digitales_y_los_criptoactivos.pdf * SUGEF: https://www.sugef.fi.cr/normativa/normativa_vigente/reglamentos_sugef/Acuerdo%20SUGEF%2011-18.pdf * The Tico Times: https://ticotimes.net/2025/06/04/money-laundering-in-costa-rica-key-methods-and-challenges
Source Evidence
Primary and secondary sources cited in this analysis
"Yes, cryptocurrency activities are legal in Costa Rica. In the absence of dedicated regulation, Costa Rica tolerates crypto activities, as long as they comply with all other existing laws and regulations."
"Cryptocurrencies are not recognized by the law as legal tender, making them legal for private transactions."
"Although their use is permitted in Costa Rica, those who wish to acquire these assets do so at their own risk... financial entities are not authorized to offer services related to cryptoassets."
"Obligated subjects that carry out activities described in articles 15 and 15 bis of Law 7786 must register."
"The purpose of this law is to regulate the market of cryptoassets... and the providers of services related to them."
"As of now, Costa Rica does not have a distinct crypto licensing regime as of 2025; in practice, crypto companies are regulated in accordance with general financial laws."
"Unregulated in Costa Rica, cryptocurrencies like Bitcoin enable anonymous transactions."
Web Sources (2)
Sources discovered via web search grounding
Search queries used (8)
- Banco Central de Costa Rica criptomonedas comunicado oficial
- Costa Rica crypto tax regulation Hacienda
- Costa Rica cryptocurrency regulation status 2024 2025
- SUGEF Costa Rica crypto assets registration requirements
- Expediente 23.415 Costa Rica estado actual
- Banco Central de Costa Rica prohibición bancos criptoactivos
- Costa Rica Law 7786 Article 15 bis virtual assets
- SUGEF Acuerdo 11-18 criptomonedas
https://coingeek.com/costa-rica-wants-crypto-taxes-removed-as-it-eyes-transformation-into-digital-asset-hub/
https://www.sugef.fi.cr/sujetos%20inscritos%20ley%207786%20-%20(%20apnfds)/informacion%20apnfd/Capacitacion%20Sugef%2011-18%20del%2018-03-2025.pdf