A new law passed in May 2026 and entering into force in September 2026 will make Costa Rica more attractive but less affordable to crypto entrepreneurs.

You may not know it, but a couple of Central American countries concentrate on thousands of crypto projects and web3 protocols. Thanks to a laissez-faire approach, forming a company is sufficient to legally operate in the crypto space. These countries are Costa Rica and Panama.

They are the literal cradle of thousands of crypto companies, the starting point, the springboard before growth. The only caveat is that, as such companies are technically left unchecked, it is nearly impossible for them to access banking, though some legal turnarounds exist.

Concerns grew about this absence of compliance enforcement. The Financial Action Task Force (FATF), notably because they authored Recommendation 15 that set the basis of Anti-Money Laundering and Countering the Financing of Terrorism (AML-CFT) regulations worldwide. For example: VARA in Dubai, MiCA in Europe.

Fearing potential consequences, Costa Rica eventually caved in, with the passing in May 2026 of the Ley 10961. The law will enter into force on September 19th, 2026.

In essence, this law imposes an AML-CFT framework to virtual asset service providers (VASP) that includes reporting obligations and the necessity in most cases to appoint a compliance officer. Crypto companies are required to register with the SUGEF, the Costa Rican authority on the matter.

The terminology of “registration” is important. In other instances of cryptocurrency business operation, the term ‘license’ can be prominent, like MiCA license for example. Those are different things. A registration is exactly what it says it is: being registered in a file. The exact activities aren’t controlled at this stage and the VASPs have to assess the legality on their own, at the risk of sanctions if their activity goes beyond the law.

There are pros and cons to this upcoming regulatory change:

• On one side, it will facilitate access to local banking, and might even facilitate access to global banking solutions;
• On the other side, implementing a compliance function in a startup implies additional costs, making Costa Rica a less affordable entry into the crypto business market.

Companies already registered and operating from Costa Rica should prepare accordingly. For example at LegalBison, a vast campaign of notifications has begun in order to ensure a smooth transition to the new regulation.

Costa Rica was considered as an entrance to the crypto industries for half a decade. History doesn’t repeat itself, but it often rhymes. One may wonder if we are witnessing a case similar to Estonia in the past: a country that went from being the central node of crypto business to just a few MiCA licenses in less than a decade.

And if Costa Rica loses its status as the leading springboard for crypto startups, one may wonder if another jurisdiction will pick up that title.

LegalBison is a global boutique legal and business consulting firm specializing in regulatory architecture for FinTech and digital asset projects. The firm provides a comprehensive suite of services, including corporate structuring, license obtainment, compliance program design, and account opening assistance. With a multi-disciplinary team of lawyers, compliance experts, and practitioners, LegalBison operates across more than 50 jurisdictions worldwide to help companies navigate complex global regulatory landscapes.