Countries › Costa Rica › Guide › 13. Regulation › Anti money laundering in Costa Rica: who is obligated, KYC, SUGEF registration and fines

Anti money laundering in Costa Rica: who is obligated, KYC, SUGEF registration and fines

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Last verified: 2026-10-30 · Status: Changing

Banks and other supervised financial entities, plus listed non financial businesses (casinos, habitual real estate dealers, precious metal dealers, lawyers, notaries and accountants acting for clients, trust providers, non bank lenders, pawnshops) and, since 19 September 2026, virtual asset service providers must register with SUGEF, know their customers, keep records for five years and report suspicious transactions at once to the UIF. Clients with bearer shares are banned. Fines reach 2% of equity for supervised entities, and 5% to 50% of the transaction or up to 100 salarios base for other obligated subjects.

USD figures use the Banco Central de Costa Rica reference selling rate of ₡454.82 per US dollar published for 29 October 2026 (indicator 318 on bccr.fi.cr), rounded to the cent. Salario base figures use ₡462,200 for 2026 (Poder Judicial Circular 246-2025 under Ley 7337 art. 2).

Key facts

KYC and transaction recording threshold	10000 USDLey 7786 art. 16(c) and 20, as of 2026-10-30 · in force
Record retention	5 yearsLey 7786 art. 16(d) and (e), as of 2026-10-30 · in force
Virtual asset service providers obligated and registered with SUGEF	yes Ley 10961 adding Ley 7786 art. 15 quater, as of 2026-10-30 · in force
Maximum fine for non financial obligated subjects (control failures)	100 salarios baseLey 7786 art. 81, as of 2026-10-30 · in force
Maximum fine for supervised financial entities	2 % of equityLey 7786 art. 81(a), as of 2026-10-30 · in force

The rule

1. Casinos, habitual real estate buyers and sellers, precious metal and stone dealers, certain non profits, people (including lawyers, notaries and accountants) who carry out real estate deals, manage client money or assets, or buy and sell legal persons for clients, trust service providers, non bank lenders and pawnshops must meet the AML obligations, register with SUGEF (registration is not an operating licence) and accept its risk based supervision.Ley 7786 (as amended by Ley 9449), art. 15 bis, 2017-05-10 official text · verified 2026-10-30

2. Virtual asset service providers must meet AML obligations and register with SUGEF; regulated entities and other obligated subjects may not deal with unregistered providers.Ley 7786, art. 15 quater added by Ley 10961, art. 15 quater, 2026-06-09 official text · verified 2026-10-30 · changed: Ley 10961 (Gaceta 113, 19 Jun 2026) added virtual asset service providers as obligated subjects, effective 19 Sep 2026.

3. Obligated subjects must identify beneficial owners when clients may not act for themselves, keep only named accounts, verify identity, representation, domicile, occupation and source of funds (especially for transactions of US$10,000 or more), and keep records for at least five years after the transaction ends.Ley 7786, art. 16(a) to (e), 1998-04-30 official text · verified 2026-10-30

4. Obligated subjects may not open accounts for or keep as clients companies with bearer shares; foreign legal persons must be registered in nominative form so that founders and shareholders can be identified.Ley 7786 (art. 16(f) as amended by Ley 10961; last paragraph by Ley 10373), art. 16(f), 2026-06-09 official text · verified 2026-10-30

5. Suspicious transactions, including transfers to or from abroad, must be reported confidentially and immediately to the Unidad de Inteligencia Financiera of the Instituto Costarricense sobre Drogas; tipping off the client is prohibited.Ley 7786 (as amended by Ley 10961), art. 25, 2026-06-09 official text · verified 2026-10-30

6. Obligated subjects must monitor UN Security Council terrorism and proliferation lists permanently and freeze assets of designated persons immediately, without prior notice, reporting to the UIF within 24 hours.Ley 7786 (as amended by Ley 10961), art. 33 bis, 2026-06-09 official text · verified 2026-10-30

7. Supervised financial entities are fined 0.5% to 2% of equity for failing to record transactions of US$10,000 or more (including multiple transactions) and for KYC, record keeping, PEP, suspicious reporting and control failures; non financial obligated subjects are fined 5% to 50% of the transaction for unrecorded US$10,000 transactions and 2 to 100 salarios base for KYC, registration, controls and reporting failures. Fines are due within eight business days, with a 3% monthly surcharge if late.
Cost to do it: 2 to 100 salarios base for non financial obligated subjects.
Example: ₡924,400 to ₡46,220,000 in 2026. / About US$2,032.45 to US$101,622.62.Ley 7786 (art. 81 as amended by Ley 10961), art. 81, 2026-06-09 official text · verified 2026-10-30

8. The salario base used for fines in laws that refer to Ley 7337 is the monthly base salary of the Oficinista 1 post in the national budget; the Poder Judicial set it at ₡462,200 for 2026.
Cost to do it: ₡462,200 per salario base in 2026.
Example: One salario base: ₡462,200. / About US$1,016.23.Ley 7337; Poder Judicial Circular 246-2025, Ley 7337 art. 2; Circular 246-2025, 2025-12-16 official text · verified 2026-10-30

9. Laundering assets that the person knows or accepts may derive from crime carries eight to twenty years in prison, and ten to twenty years where the source is drugs, terrorism, trafficking, environmental crime, tax or customs fraud, smuggling or corruption.Ley 7786 (as amended by Ley 10373), art. 69, 2023-09-20 official text · verified 2026-10-30

Worked example

A real estate brokerage that habitually buys and sells property registers with SUGEF. It closes a US$300,000 cash funded sale (about ₡136,446,000) without completing the transaction form. Under art. 81 it faces 5% to 50% of the transaction, US$15,000 to US$150,000 (about ₡6,822,300 to ₡68,223,000). Weak KYC files would add 2 to 100 salarios base, ₡924,400 to ₡46,220,000 in 2026.

Step by step

Check whether any activity falls under art. 15 bis or 15 quater, and register with SUGEF before operating.
Adopt a risk based KYC manual, beneficial owner checks and source of funds evidence.
Record transactions of US$10,000 or more, including split transactions.
Screen clients against UN lists continuously and set a 24 hour freezing and reporting procedure.
Report suspicious activity to the UIF immediately and train staff not to tip off clients.

Common traps

Registration with SUGEF does not authorise the business to operate in a regulated activity.
Banks will not open accounts for entities with bearer shares.
Dealing with an unregistered obligated subject is itself sanctionable.
Lawyers, notaries and accountants are obligated only for the listed activities, but those include company sales and managing client funds.

Sources

← Anti corruption and corporate criminal liability in Costa Rica: Ley 9699 and compliance programmesEnvironmental liability and waste in Costa Rica: polluter pays, Tribunal Ambiental and waste duties →

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