Costa Rica VASP Company Registration

Costa Rica currently does not require a dedicated virtual asset service provider license for companies wishing to include cryptocurrency and digital asset activities in their corporate purpose. A standard Costa Rican corporation — structured as an S.A. (Sociedad Anónima) or S.R.L. — can explicitly include virtual asset activities in its corporate objects, covering exchange, wallet operations, OTC dealing, remittance, and related services, without government licensing approval.

This makes Costa Rica one of the most accessible jurisdictions globally for virtual asset companies in the formation stage — particularly for startups, exchanges, wallet providers, and OTC desks that need a regulated corporate base and AML/CFT compliance framework while their business model is still developing, or that are operating internationally without targeting Costa Rican domestic clients.

What Is Required — UAF AML/CFT Registration

While no VASP license is required, registration with the Unidad de Análisis Financiero (UAF) under Law 23 of 2015 is mandatory for all entities conducting virtual asset activities in Costa Rica. UAF registration imposes AML/CFT obligations including Know Your Customer procedures, customer due diligence, source of funds verification, suspicious transaction reporting to the Financial Intelligence Unit, and appointment of a compliance officer. These requirements are substantive and non-negotiable — operating without UAF registration while conducting virtual asset activities is a regulatory violation.

Corporate Structure

Costa Rican corporations require at least three directors, who need not be residents — foreign nationals serve as directors without local presence requirements. Corporate documents are issued in Spanish, with English translations typically provided for international clients. Business objects such as "operations with virtual currencies" and "digital asset exchange services" can be explicitly included in the Memorandum and Articles at formation. A legal opinion from local counsel confirming the legality of the specific virtual asset activities under current Costa Rican law is available and recommended for banking and compliance purposes.

Tax Position

Costa Rica operates a territorial tax system. Income generated outside Costa Rica by a Costa Rican entity is not subject to Costa Rican corporate income tax. For virtual asset companies serving international clients with no Costa Rican domestic operations, this means an effective 0% tax rate on offshore income — one of the most favourable tax positions available for a corporate-registered entity in Latin America.

Regulatory Outlook — SUGEF Registration Bills

As of April 2026, bills requiring formal VASP registration with SUGEF (Superintendencia General de Entidades Financieras) have advanced in the Costa Rican legislature but have not yet become law. The current status remains that no specific VASP license is required for companies including virtual asset activities in their corporate purpose, provided UAF registration is maintained. Zitadelle AG monitors regulatory developments in Costa Rica and will update clients as the legislative position evolves.

How Zitadelle AG Assists

Zitadelle AG assists with Costa Rica company formation — covering corporate structuring (S.A. or S.R.L.), corporate object drafting to include virtual asset activities, UAF registration support, legal opinion coordination, and AML/CFT compliance framework preparation. For operators evaluating Costa Rica alongside other low-barrier virtual asset jurisdictions, we also provide comparative analysis against Panama, SVG, and Seychelles.