Regulatory changes we're tracking and practical guides from the team that prepares the applications.
Regulatory updates
Costa Rica enacted Legislative Decree No. 10961 on May 27 2026, amending Law No. 7786 to add VASPs as obligated AML/CFT subjects for the first time. SUGEF registration mandatory. Banking exclusion for unregistered VASPs. Penalties USD $1,800–$90,000. CONASSIF implementing regulations expected within 3 months of La Gaceta publication.
Crypto & MiCA
B2BINPAY, Binance, Tether, Freedx, and Finprime.pro are CNAD-licensed. Why the El Salvador DASP is gaining traction with non-EU, non-US crypto operators targeting LatAm and emerging markets.
Crypto & MiCAUpdated
Costa Rica and Panama remain the last major jurisdictions without mandatory VASP licensing in 2026. Bill 22.837 (Costa Rica) and Bills 247 and 326 (Panama) are both moving through legislatures. Panama exited EU high-risk list July 2025. CARF reporting from 2027. The honest timeline for how long this window stays open.
Regulatory updates
The Superintendency of Banks of Panama has officially confirmed that Kunaisa / Kunaisa License has never held any banking or fiduciary authorization in Panama. Official confirmation published. Industry notice by Zitadelle AG.
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