VASPs Included in Costa Rica’s AML Framework Under Law No. 7786

Published on Aug 13, 2026


Michael Villalobos, Senior Associate at ARIAS Costa Rica, experts in FinTech, share this article on:

The inclusion of Virtual Asset Service Providers (VASPs) within the preventive framework of Law No. 7786 marks a turning point for the FinTech ecosystem in Costa Rica.

Costa Rica is taking an important step towards adopting international standards on the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction.

For the first time, Virtual Asset Service Providers (VASPs) are now subject to the existing regulatory framerork against money laundering under Law No. 7786, which entails specific compliance obligations, including:

  • Implement robust customer identification and know-your-customer (KYC) processes.
  • Identify and verify ultimate beneficial owners.
  • Apply a risk-based approach to the management of customers, products and operations.
  • Monitor transactions and maintain records.
  • Report suspicious transactions to the ICD’s Financial Intelligence Unit.
  • Comply with SUGEF registration requirements, where applicable.

However, it is important to clarify that this reform does not constitute comprehensive regulation of the virtual asset market. Registration with SUGEF does not amount to a license to operate, nor does it imply authorization or validation of the business model. Its purpose is to incorporate these entities into the national anti-money laundering system, thereby strengthening the transparency and traceability of transactions.

From a practical perspective, this reform will also have an impact on the relationship between PSAVs and financial institutions and other regulated entities, as regulatory compliance and the relevant registration will become key factors in due diligence and risk management processes.

Some recommendations for operators in the sector:

  1. Assess whether the business model falls within the legal definition of a PSAV.
  2. Carry out a compliance gap assessment to identify the adjustments required considering the new obligations.
  3. Strengthen compliance programs through KYC policies, transaction monitoring, risk management and record-keeping.
  4. Train staff in the prevention of money laundering and terrorist financing.
  5. Monitor the regulations to be issued by CONASSIF, which will set out key operational aspects for the implementation of the new regime.

This reform represents a significant step forward for the country. Whilst there is not yet a comprehensive regulatory framework for virtual assets, the inclusion of PSAVs within the preventive regime of Law No. 7786 strengthens legal certainty, promotes best compliance practices and brings Costa Rica closer to the international standards promoted by the FATF.

The real challenge will not only be to comply with new legal obligations, but also to develop business models that integrate technological innovation with a robust culture of compliance, transparency and risk management. Striking this balance will be crucial to consolidating a more competitive, reliable and sustainable FinTech ecosystem.