VASP Company Without License — Costa Rica & Panama
Unregulated offshore crypto structures — honest assessment of use cases and limitations
— Last updated: January 2026 · 5 min read
Overview
Costa Rica and Panama both offer offshore corporate structures that can be used for crypto businesses without a mandatory VASP license. Both jurisdictions have no specific VASP licensing regimes. This guide explains the practical use cases, limitations, and when these structures are and are not appropriate.
Costa Rica Features
- •No income tax on foreign-sourced income
- •Well-established offshore service sector
- •No VASP license required for foreign-client-only operations
- •AML/CFT compliance still recommended
Panama Features
- •Sociedad Anónima (S.A.) widely used
- •Strong privacy framework
- •No specific VASP law
- •Foreign-sourced income tax exempt
When These Structures Are Appropriate
- •Technology or holding entities behind a regulated front entity
- •Personal investment vehicles
- •Non-client-facing infrastructure
- •Transition structures while pursuing a regulated license
Honest Assessment
Unregulated offshore structures for crypto have significant limitations — restricted banking access, no institutional counterparty acceptance, client trust challenges, and potential regulatory risk as global VASP frameworks tighten. Zitadelle AG recommends these structures only for specific use cases where regulatory authorization is genuinely unnecessary.
Frequently Asked Questions
Both countries do not currently require specific crypto licenses for foreign-client-only operations. However, AML/CFT obligations under local law may still apply, and banking access is significantly limited without a regulated license.
Need an Honest Assessment?
Contact Zitadelle AG for a candid evaluation of whether Costa Rica or Panama is appropriate for your crypto business.
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Disclaimer: This page is for informational purposes only and does not constitute legal or regulatory advice. Requirements, timelines, and fees are subject to change. Always consult directly with the relevant regulatory authority or a qualified professional for the most current information. Zitadelle Advisory Group LTD is not a law firm and does not provide legal representation.