Costa Rica
Retail_Trading_Status
- Analysis ID
- #85
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- Archived
- Created
- 2025-04-12 06:43
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Executive Summary
Costa Rica allows retail cryptocurrency trading in an unregulated environment, as activities not explicitly prohibited are permitted. The primary regulator, Banco Central de Costa Rica (BCCR), does not recognize cryptocurrencies as legal tender. Businesses involved in crypto must comply with general AML/CFT regulations. A proposed "Crypto Asset Market Law" introduced around 2022 has stalled, leaving ambiguity, though Banco Nacional launched a spot Bitcoin ETF in early 2025.
Key Pillars
- Primary regulator: Banco Central de Costa Rica (BCCR) clarifies its position but does not provide specific crypto regulation.
- Core compliance requirements: AML/CFT policies, KYC procedures aligning with FATF recommendations.
- Licensing: No specific "crypto license" is issued, but businesses must comply with general financial service legislation.
- The General Superintendency of Financial Institutions (SUGEF), under the direction of the National Council for Supervision of the Financial System (CONASSIF), could extend its oversight to crypto-related activities.
Landmark Laws
- Crypto Asset Market Law (Proposed around 2022): Aimed to establish a clearer framework, define crypto use for payments (without granting legal tender status), and address regulatory gaps; however, it has stalled in the legislative process.
Considerations
- Cryptocurrencies are not recognized as legal tender by the BCCR.
- Crypto transactions are carried out at the user's own risk, with concerns about volatility, fraud, and lack of consumer protection.
- The lack of specific regulation creates uncertainty and challenges, particularly regarding access to traditional banking services.
- Businesses must comply with existing general financial regulations, particularly those concerning AML/CFT.
- A "Crypto Asset Market Law" proposed in 2022 has stalled, leaving the regulatory landscape ambiguous.
Notes
- The BCCR issued a statement in October 2017 that Bitcoin and cryptocurrencies are not considered currencies and are not backed by law.
- A "laissez-faire" or "vigilant tolerance" approach makes Costa Rica attractive for some crypto businesses due to low setup barriers.
- Banco Nacional announced the launch of a spot Bitcoin ETF in early 2025.
- Legal workarounds exist, such as using the principle of freedom of contract to trade and use cryptocurrencies based on mutual agreement between parties.
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading in Costa Rica is currently Allowed-UnRegulated. There is no specific legal framework dedicated solely to regulating cryptocurrencies or crypto-asset service providers. The Central Bank of Costa Rica (BCCR) does not recognize cryptocurrencies as legal tender and has stated that they are not backed by the government or the national banking system. Transactions involving cryptocurrencies cannot be processed through the National Electronic Payment System (SINPE). The BCCR emphasizes that individuals engaging with cryptocurrencies do so at their own risk, highlighting potential issues like volatility and fraud. Despite the lack of specific crypto regulation, cryptocurrency activities are not illegal. Individuals are free to trade, hold, and use cryptocurrencies based on mutual agreement between parties, leveraging the principle of freedom of contract. This has led to cryptocurrencies being used in various transactions, including real estate deals. Some businesses accept crypto payments, and there have been discussions about paying salaries in crypto, classifying it as a "commonly accepted asset" under the Labor Code.
Businesses involved in cryptocurrency are not entirely free from oversight. They must comply with existing general financial regulations, particularly those concerning Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT). Entities may fall under the purview of general financial services legislation and are expected to implement robust KYC policies, often aligning with international standards like those recommended by the Financial Action Task Force (FATF). The General Superintendency of Financial Institutions (SUGEF), under the direction of the National Council for Supervision of the Financial System (CONASSIF), is the primary regulator for financial institutions, and its oversight could extend to crypto-related activities falling under existing financial definitions. The Financial Intelligence Unit (UIF) also plays a role in monitoring suspicious transactions.
A bill known as the "Crypto Asset Market Law" was proposed around 2022, aiming to establish a clearer framework. However, as of early 2025, this legislation appears to have stalled, leaving the regulatory landscape in its current state of ambiguity. This "laissez-faire" approach makes Costa Rica attractive for some crypto businesses due to low setup barriers. However, the lack of specific regulation also creates uncertainty and challenges, particularly regarding access to traditional banking services.
A notable development in early 2025 was the announcement by Banco Nacional, Costa Rica's largest state-owned commercial bank, to launch a spot Bitcoin Exchange-Traded Fund (ETF) through its investment arm. This allows Costa Ricans regulated access to Bitcoin exposure via the traditional financial system, signaling growing institutional acceptance. The Wikipedia source cited summarizes the BCCR's 2017 statement indicating that Bitcoin and cryptocurrencies are not considered currencies, are not backed by law, and cannot be traded on Costa Rica's national payment system.
Summary Points
Okay, here's the regulatory analysis of Retail_Trading_Status in Costa Rica, converted into a clear, well-structured bullet point format:
Retail Cryptocurrency Trading Status in Costa Rica: Regulatory Analysis (April 12, 2025)
I. Overall Regulatory Status:
- Allowed-Unregulated: Retail cryptocurrency trading is permitted but operates without a dedicated regulatory framework specific to crypto-assets.
II. Key Regulatory Bodies and Their Roles:
- Central Bank of Costa Rica (Banco Central de Costa Rica - BCCR):
- Does not recognize cryptocurrencies as legal tender.
- States cryptocurrencies are not backed by the government or national banking system.
- Prohibits crypto transactions through the National Electronic Payment System (SINPE).
- Emphasizes that crypto activities are undertaken at the user's own risk (volatility, fraud, lack of consumer protection).
- General Superintendency of Financial Institutions (SUGEF):
- Primary regulator for financial institutions.
- Oversight could extend to crypto-related activities falling under existing financial definitions.
- Operates under the direction of the National Council for Supervision of the Financial System (CONASSIF).
- Financial Intelligence Unit (UIF):
- Monitors suspicious transactions, which could include those involving cryptocurrencies.
III. Important Legislation and Regulations:
- No Specific Crypto Legislation: Currently, no comprehensive legal framework specifically regulates cryptocurrencies or crypto-asset service providers (VASPs).
- General Financial Regulations Apply: Existing general financial regulations, particularly those concerning Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT), indirectly regulate crypto activities.
- Freedom of Contract: Costa Rican civil law emphasizes freedom of contract, allowing individuals and businesses to use cryptocurrencies for transactions if both parties consent.
- Stalled Legislation: The "Crypto Asset Market Law" (proposed around 2022) aimed to establish a clearer framework but has stalled in the legislative process.
IV. Requirements for Compliance:
- AML/CFT Compliance: Businesses involved in cryptocurrency must comply with existing AML/CFT regulations.
- KYC (Know Your Customer) Policies: Expected to implement robust KYC policies.
- Alignment with International Standards: Often align with international standards like those recommended by the Financial Action Task Force (FATF).
V. Notable Restrictions or Limitations:
- No Legal Tender Status: Cryptocurrencies are not legal tender and are not legally required to be accepted as payment.
- Lack of Government Backing: Cryptocurrencies are not backed by the government or the national banking system.
- Limited Consumer Protection: Lack of specific consumer protection mechanisms tailored to crypto-assets.
- Banking Challenges: Difficulty accessing traditional banking services, as banks may be hesitant to engage with crypto firms operating in an unregulated environment.
VI. Recent Developments or Changes:
- Banco Nacional Bitcoin ETF: Banco Nacional, a state-owned commercial bank, launched a spot Bitcoin Exchange-Traded Fund (ETF) through its investment arm in early 2025. This provides regulated access to Bitcoin exposure via the traditional financial system.
- Continued Regulatory Ambiguity: Despite the ETF development, the overall regulatory landscape remains unclear due to the lack of specific crypto legislation.
Full Analysis Report
Full Analysis Report
Report: Retail Cryptocurrency Trading Status in Costa Rica
Date: April 12, 2025
Prepared For: Internal Review
Prepared By: Financial Regulatory Analyst
Topic: Retail_Trading_Status
1. Current Status: Allowed-UnRegulated
2. Detailed Narrative Explanation:
Costa Rica permits individual citizens and residents to buy, sell, and hold cryptocurrencies. The country currently operates under a principle where activities not explicitly prohibited by law are generally allowed. As there is no specific, comprehensive legal framework dedicated solely to regulating cryptocurrencies or crypto-asset service providers (VASPs), retail trading exists in a space largely devoid of targeted crypto regulation.
The Central Bank of Costa Rica (Banco Central de Costa Rica - BCCR) has clarified its position on several occasions. It does not recognize cryptocurrencies as legal tender, meaning they are not official currency like the Costa Rican Colón (CRC) or the US Dollar, and no one is legally obligated to accept them as payment [8, 9]. Furthermore, the BCCR has stated that cryptocurrencies are not backed by the government or the national banking system, and transactions involving them cannot be processed through the National Electronic Payment System (SINPE) [4, 9, 13]. The BCCR emphasizes that individuals or entities engaging with cryptocurrencies do so entirely at their own risk, highlighting potential issues like volatility, fraud, and the lack of specific consumer protection mechanisms tailored to crypto-assets [4, 5].
Despite the lack of specific crypto regulation and the BCCR's cautionary stance, cryptocurrency activities are not illegal [3, 8]. Individuals are free to trade, hold, and use cryptocurrencies based on mutual agreement between parties, leveraging the principle of freedom of contract enshrined in Costa Rican civil law [8]. This has led to cryptocurrencies being used in various transactions, including real estate deals, particularly among foreign investors and tech-savvy locals [5, 8]. Some businesses even accept crypto payments, and there have been discussions about the legality of paying salaries (above the minimum wage portion) in crypto, classifying it as a "commonly accepted asset" under the Labor Code, though this requires careful handling of social security contributions based on fluctuating values [9, 13].
While there isn't a specific "crypto license" issued by Costa Rican authorities, businesses involved in cryptocurrency (such as exchanges or platforms facilitating trades) are not entirely free from oversight [2, 3]. They must comply with existing general financial regulations, particularly those concerning Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) [2, 3, 5]. Entities may fall under the purview of general financial services legislation and are expected to implement robust KYC (Know Your Customer) and AML/CFT policies, often aligning with international standards like those recommended by the Financial Action Task Force (FATF) [3, 10]. The General Superintendency of Financial Institutions (SUGEF), under the direction of the National Council for Supervision of the Financial System (CONASSIF), is the primary regulator for financial institutions, and its oversight could extend to crypto-related activities falling under existing financial definitions [2, 14]. The Financial Intelligence Unit (UIF) also plays a role in monitoring suspicious transactions, which could include those involving crypto [5].
There have been legislative attempts to bring more clarity. A bill known as the "Crypto Asset Market Law" was proposed (reportedly around 2022) aiming to establish a clearer framework, define crypto use for payments (without granting legal tender status), and potentially address regulatory gaps [6, 7]. However, as of early 2025, this legislation appears to have stalled, leaving the regulatory landscape in its current state of ambiguity [6].
This "laissez-faire" or "vigilant tolerance" approach [3, 9] makes Costa Rica attractive for some crypto businesses due to low setup barriers [3]. However, the lack of specific regulation also creates uncertainty and challenges, particularly regarding access to traditional banking services, as banks may be hesitant to engage with crypto firms operating in an unregulated environment [5].
A notable development in early 2025 was the announcement by Banco Nacional, Costa Rica's largest state-owned commercial bank, to launch a spot Bitcoin Exchange-Traded Fund (ETF) through its investment arm. This allows Costa Ricans regulated access to Bitcoin exposure via the traditional financial system, signaling growing institutional acceptance within the existing (non-crypto-specific) regulatory framework [6].
In summary, retail crypto trading is allowed but operates without a dedicated regulatory framework specific to crypto-assets in Costa Rica. While not illegal and permitted under general legal principles, it lacks official backing, specific consumer protections, and clear rules beyond the application of general AML/CFT requirements.
3. Relevant Text Excerpts:
- On Lack of Specific Regulation: "Currently, Costa Rica does not have specific legislation aimed at regulating cryptocurrencies. However, general economic and financial regulations, as well as anti-money laundering (AML) and financing of terrorism (CFT) laws indirectly regulate activities related to digital assets." (Source: Regulated United Europe [2])
- On Legality & Freedom of Contract: "In Costa Rica, 'the law allows everything that is not expressly prohibited.' That means any citizen can trade in crypto, own crypto, provide crypto-related services, because there is currently no law prohibiting these activities.” (Source: Blue Water Properties, quoting attorney Adrián Obando [7]) / "Freedom of Contract: Costa Rica's legal framework emphasizes the freedom of parties to contract. This means that individuals or businesses can agree to use Bitcoin or other cryptocurrencies for payments or transactions if both parties consent." (Source: Quatro Legal [8])
- On BCCR Stance: "In October 2017, the Central Bank of Costa Rica issued a statement that Bitcoin and cryptocurrencies are not considered currencies, are not backed by law, and cannot be traded on Costa Rica's national payment system. The Central Bank emphasized that anyone who used cryptocurrency did so at their own risk." (Source: Wikipedia, summarizing BCCR statement [4]) / "The Banco Central de Costa Rica (BCCR) does not recognise cryptocurrencies as legal tender but allows for their use under private agreements. It has issued statements clarifying that crypto transactions are carried out at the user's own risk..." (Source: Kryptomoney [5])
- On AML/KYC Requirements: "Compliance with AML/CFT policies: Although there are no specialised requirements, companies are required to develop and implement strict AML/CFT policies." (Source: Regulated United Europe [2]) / "Crypto businesses in Costa Rica must comply with broader financial regulations, particularly those that concern anti-money laundering (AML) and consumer protection laws." (Source: Kryptomoney [5]) / "It is advised to follow the FATF Recommendations on AML-CFT and KYC to avoid potentially serious consequences." (Source: LegalBison [3])
- On Regulatory Uncertainty/Stalled Legislation: "Despite the country's ever-growing crypto market, the local regulatory landscape remains unclear. There is no specific legal framework established for cryptocurrencies... For that reason, businesses and individuals can use cryptocurrencies without legal restrictions, but it also creates regulatory uncertainty." (Source: Kryptomoney [5]) / "In 2022, lawmakers introduced the Crypto Asset Market Law... However, the bill has stalled in the legislative process, leaving the country's crypto policies in limbo." (Source: Finance Magnates [6])
- On Institutional Acceptance (ETF): "Banco Nacional... is set to launch a spot Bitcoin exchange-traded fund (ETF) through its investment arm... This move marks the first time Costa Ricans will have access to a crypto investment product through the traditional banking system..." (Source: Finance Magnates [6])
4. Source URLs:
- (General Time Info - Not directly used for content)
https://rue.ee/en/news/crypto-license-in-costa-rica(Regulated United Europe - Discusses licensing context, AML)https://legalbison.com/crypto-license/costa-rica/(LegalBison - Discusses legality, laissez-faire approach, AML/KYC)https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory#Costa_Rica(Wikipedia - Summarizes BCCR 2017 stance)https://kryptomoney.com/regulation-of-costa-rica-cryptocurrency-industry/(Kryptomoney - Discusses lack of framework, BCCR position, AML, uncertainty)https://www.financemagnates.com/cryptocurrency/regulation/bitcoin-enters-costa-ricas-banking-system-with-new-etf/(Finance Magnates - Reports on Banco Nacional ETF, stalled legislation)https://www.bluewaterpropertiesofcostarica.com/blog/is-crypto-regulated-in-costa-rica-buy-real-estate-with-bitcoin/(Blue Water Properties - Quotes lawyer on legality principle, mentions proposed law)https://quatrolaw.com/digital-assets-real-estate-transactions-in-costa-rica/(Quatro Legal - Discusses lack of regulation, BCCR stance, freedom of contract)https://manimama.com/cryptocurrency-regulation-in-costa-rica/(Manimama Law Firm - Discusses BCCR directives, legality, AML interpretation)https://legalnodes.com/article/vasp-license-guide(Legal Nodes - Mentions Costa Rica's simplified requirements, AML/CFT compliance)https://www.multilaw.com/Multilaw/Multilaw_Member_Firms/Zurcher_Odio_Raven_Costa_Rica/Multilaw/Practice_Area_Guides/Costa_Rica_ICO_token_sale.aspx(Multilaw - Focuses on ICOs, notes lack of specific regulation but need to consider AML/financial laws)- (Consortium Legal - General Fintech context, not specific to crypto retail status)
https://freemanlaw.com/costa-rica-and-cryptocurrency/(Freeman Law - Discusses "crypto haven" aspects, payment in crypto, BCCR stance)https://chambers.com/content/item/10887(Chambers and Partners - Describes general banking regulatory structure, SUGEF/CONASSIF roles)
**Report: Retail Cryptocurrency Trading Status in Costa Rica** **Date:** April 12, 2025 **Prepared For:** Internal Review **Prepared By:** Financial Regulatory Analyst **Topic: Retail_Trading_Status** **1. Current Status:** `Allowed-UnRegulated` **2. Detailed Narrative Explanation:** Costa Rica permits individual citizens and residents to buy, sell, and hold cryptocurrencies. The country currently operates under a principle where activities not explicitly prohibited by law are generally allowed. As there is no specific, comprehensive legal framework dedicated solely to regulating cryptocurrencies or crypto-asset service providers (VASPs), retail trading exists in a space largely devoid of targeted crypto regulation. The Central Bank of Costa Rica (Banco Central de Costa Rica - BCCR) has clarified its position on several occasions. It does not recognize cryptocurrencies as legal tender, meaning they are not official currency like the Costa Rican Colón (CRC) or the US Dollar, and no one is legally obligated to accept them as payment [8, 9]. Furthermore, the BCCR has stated that cryptocurrencies are not backed by the government or the national banking system, and transactions involving them cannot be processed through the National Electronic Payment System (SINPE) [4, 9, 13]. The BCCR emphasizes that individuals or entities engaging with cryptocurrencies do so entirely at their own risk, highlighting potential issues like volatility, fraud, and the lack of specific consumer protection mechanisms tailored to crypto-assets [4, 5]. Despite the lack of specific crypto regulation and the BCCR's cautionary stance, cryptocurrency activities are not illegal [3, 8]. Individuals are free to trade, hold, and use cryptocurrencies based on mutual agreement between parties, leveraging the principle of freedom of contract enshrined in Costa Rican civil law [8]. This has led to cryptocurrencies being used in various transactions, including real estate deals, particularly among foreign investors and tech-savvy locals [5, 8]. Some businesses even accept crypto payments, and there have been discussions about the legality of paying salaries (above the minimum wage portion) in crypto, classifying it as a "commonly accepted asset" under the Labor Code, though this requires careful handling of social security contributions based on fluctuating values [9, 13]. While there isn't a specific "crypto license" issued by Costa Rican authorities, businesses involved in cryptocurrency (such as exchanges or platforms facilitating trades) are not entirely free from oversight [2, 3]. They must comply with existing general financial regulations, particularly those concerning Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) [2, 3, 5]. Entities may fall under the purview of general financial services legislation and are expected to implement robust KYC (Know Your Customer) and AML/CFT policies, often aligning with international standards like those recommended by the Financial Action Task Force (FATF) [3, 10]. The General Superintendency of Financial Institutions (SUGEF), under the direction of the National Council for Supervision of the Financial System (CONASSIF), is the primary regulator for financial institutions, and its oversight could extend to crypto-related activities falling under existing financial definitions [2, 14]. The Financial Intelligence Unit (UIF) also plays a role in monitoring suspicious transactions, which could include those involving crypto [5]. There have been legislative attempts to bring more clarity. A bill known as the "Crypto Asset Market Law" was proposed (reportedly around 2022) aiming to establish a clearer framework, define crypto use for payments (without granting legal tender status), and potentially address regulatory gaps [6, 7]. However, as of early 2025, this legislation appears to have stalled, leaving the regulatory landscape in its current state of ambiguity [6]. This "laissez-faire" or "vigilant tolerance" approach [3, 9] makes Costa Rica attractive for some crypto businesses due to low setup barriers [3]. However, the lack of specific regulation also creates uncertainty and challenges, particularly regarding access to traditional banking services, as banks may be hesitant to engage with crypto firms operating in an unregulated environment [5]. A notable development in early 2025 was the announcement by Banco Nacional, Costa Rica's largest state-owned commercial bank, to launch a spot Bitcoin Exchange-Traded Fund (ETF) through its investment arm. This allows Costa Ricans regulated access to Bitcoin exposure via the traditional financial system, signaling growing institutional acceptance within the existing (non-crypto-specific) regulatory framework [6]. In summary, retail crypto trading is allowed but operates without a dedicated regulatory framework specific to crypto-assets in Costa Rica. While not illegal and permitted under general legal principles, it lacks official backing, specific consumer protections, and clear rules beyond the application of general AML/CFT requirements. **3. Relevant Text Excerpts:** * **On Lack of Specific Regulation:** "Currently, Costa Rica does not have specific legislation aimed at regulating cryptocurrencies. However, general economic and financial regulations, as well as anti-money laundering (AML) and financing of terrorism (CFT) laws indirectly regulate activities related to digital assets." (Source: Regulated United Europe [2]) * **On Legality & Freedom of Contract:** "In Costa Rica, 'the law allows everything that is not expressly prohibited.' That means any citizen can trade in crypto, own crypto, provide crypto-related services, because there is currently no law prohibiting these activities.” (Source: Blue Water Properties, quoting attorney Adrián Obando [7]) / "Freedom of Contract: Costa Rica's legal framework emphasizes the freedom of parties to contract. This means that individuals or businesses can agree to use Bitcoin or other cryptocurrencies for payments or transactions if both parties consent." (Source: Quatro Legal [8]) * **On BCCR Stance:** "In October 2017, the Central Bank of Costa Rica issued a statement that Bitcoin and cryptocurrencies are not considered currencies, are not backed by law, and cannot be traded on Costa Rica's national payment system. The Central Bank emphasized that anyone who used cryptocurrency did so at their own risk." (Source: Wikipedia, summarizing BCCR statement [4]) / "The Banco Central de Costa Rica (BCCR) does not recognise cryptocurrencies as legal tender but allows for their use under private agreements. It has issued statements clarifying that crypto transactions are carried out at the user's own risk..." (Source: Kryptomoney [5]) * **On AML/KYC Requirements:** "Compliance with AML/CFT policies: Although there are no specialised requirements, companies are required to develop and implement strict AML/CFT policies." (Source: Regulated United Europe [2]) / "Crypto businesses in Costa Rica must comply with broader financial regulations, particularly those that concern anti-money laundering (AML) and consumer protection laws." (Source: Kryptomoney [5]) / "It is advised to follow the FATF Recommendations on AML-CFT and KYC to avoid potentially serious consequences." (Source: LegalBison [3]) * **On Regulatory Uncertainty/Stalled Legislation:** "Despite the country's ever-growing crypto market, the local regulatory landscape remains unclear. There is no specific legal framework established for cryptocurrencies... For that reason, businesses and individuals can use cryptocurrencies without legal restrictions, but it also creates regulatory uncertainty." (Source: Kryptomoney [5]) / "In 2022, lawmakers introduced the Crypto Asset Market Law... However, the bill has stalled in the legislative process, leaving the country's crypto policies in limbo." (Source: Finance Magnates [6]) * **On Institutional Acceptance (ETF):** "Banco Nacional... is set to launch a spot Bitcoin exchange-traded fund (ETF) through its investment arm... This move marks the first time Costa Ricans will have access to a crypto investment product through the traditional banking system..." (Source: Finance Magnates [6]) **4. Source URLs:** 1. *(General Time Info - Not directly used for content)* 2. `https://rue.ee/en/news/crypto-license-in-costa-rica` (Regulated United Europe - Discusses licensing context, AML) 3. `https://legalbison.com/crypto-license/costa-rica/` (LegalBison - Discusses legality, laissez-faire approach, AML/KYC) 4. `https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory#Costa_Rica` (Wikipedia - Summarizes BCCR 2017 stance) 5. `https://kryptomoney.com/regulation-of-costa-rica-cryptocurrency-industry/` (Kryptomoney - Discusses lack of framework, BCCR position, AML, uncertainty) 6. `https://www.financemagnates.com/cryptocurrency/regulation/bitcoin-enters-costa-ricas-banking-system-with-new-etf/` (Finance Magnates - Reports on Banco Nacional ETF, stalled legislation) 7. `https://www.bluewaterpropertiesofcostarica.com/blog/is-crypto-regulated-in-costa-rica-buy-real-estate-with-bitcoin/` (Blue Water Properties - Quotes lawyer on legality principle, mentions proposed law) 8. `https://quatrolaw.com/digital-assets-real-estate-transactions-in-costa-rica/` (Quatro Legal - Discusses lack of regulation, BCCR stance, freedom of contract) 9. `https://manimama.com/cryptocurrency-regulation-in-costa-rica/` (Manimama Law Firm - Discusses BCCR directives, legality, AML interpretation) 10. `https://legalnodes.com/article/vasp-license-guide` (Legal Nodes - Mentions Costa Rica's simplified requirements, AML/CFT compliance) 11. `https://www.multilaw.com/Multilaw/Multilaw_Member_Firms/Zurcher_Odio_Raven_Costa_Rica/Multilaw/Practice_Area_Guides/Costa_Rica_ICO_token_sale.aspx` (Multilaw - Focuses on ICOs, notes lack of specific regulation but need to consider AML/financial laws) 12. *(Consortium Legal - General Fintech context, not specific to crypto retail status)* 13. `https://freemanlaw.com/costa-rica-and-cryptocurrency/` (Freeman Law - Discusses "crypto haven" aspects, payment in crypto, BCCR stance) 14. `https://chambers.com/content/item/10887` (Chambers and Partners - Describes general banking regulatory structure, SUGEF/CONASSIF roles)