Costa Rica doesn’t have a law that says you can’t use Bitcoin. It also doesn’t have a law that says you can. That’s the heart of the matter. In 2025, if you’re running a crypto exchange, a GameFi platform, or even just holding NFTs in San José, you’re operating in a legal gray zone - not illegal, not fully legal, just… tolerated. And that’s exactly why so many crypto startups are setting up shop here.
Bitcoin Isn’t Money Here - But You Can Still Use It
The Central Bank of Costa Rica made it clear back in 2017: cryptocurrencies aren’t legal tender. That means no one has to accept Bitcoin for your coffee, and you can’t pay taxes with Ethereum. But here’s the twist - nobody’s stopping you from doing it anyway. Private transactions between individuals? Totally fine. You can send Solana to a friend, buy a laptop with Dogecoin, or trade NFTs over WhatsApp. The government doesn’t care - as long as it’s not tied to crime. This isn’t a loophole. It’s a deliberate silence. While countries like El Salvador made Bitcoin legal tender, Costa Rica chose to look the other way. No ban. No rules. Just a quiet shrug.The 2025 Legislative Shift: A Crack in the Gray
On July 2, 2025, things started to change. Costa Rica’s Legislative Assembly passed the first debate of Bill 22.837 - a major update to the country’s anti-money laundering laws. For the first time, virtual asset service providers (VASPs) are being formally brought into the regulatory fold. Under this new framework, any company offering crypto exchange, custody, or transfer services must register with SUGEF, the national financial supervisor. That includes decentralized exchanges, crypto casinos, and NFT marketplaces that handle real money. Registration means you must:- Verify your customers’ identities (KYC)
- Keep detailed records of every transaction for at least five years
- Flag suspicious activity and report it
- Conduct regular risk assessments, especially for users from high-risk countries
Who’s Really Running Crypto in Costa Rica?
Costa Rica’s gray area has become a magnet for low-cost, high-speed crypto ventures. Startups from the U.S., Europe, and Asia are setting up shell companies here because it’s cheaper and faster than anywhere else in Latin America. No minimum capital required. No need to hire local directors. No physical office mandate. You can incorporate a company online in under 48 hours, open a corporate bank account (if you can find a bank willing to work with you), and start trading crypto within days. This is why GameFi platforms, crypto casinos, and decentralized finance (DeFi) projects dominate the local scene. Many of them use Costa Rica’s existing gaming license framework as a backdoor to operate VASPs. The two systems overlap so much that some operators just get one license and call it a day. The result? Costa Rica is now one of the top five jurisdictions in Latin America for crypto startups - not because it’s the safest, but because it’s the easiest.
The Hidden Risks of Operating in the Gray
Easy doesn’t mean safe. The lack of clear rules means you’re flying blind. If you’re running a crypto exchange and your customer gets arrested for money laundering, you could be dragged into the investigation - even if you followed all the AML steps. Why? Because without explicit legal protection, courts can interpret your activity as unlicensed financial services. Banks might freeze your accounts. Payment processors might cut you off. Investors might pull out. And then there’s the banking problem. Most local banks still won’t touch crypto companies. Even if you’re registered with SUGEF, you’ll likely need to use offshore banking or work with fintech partners that specialize in high-risk clients. That adds cost, complexity, and delays. The Central Bank’s 2017 statement is your only shield. But it’s thin. It says crypto isn’t legal tender - not that it’s legal to run a business with it. That distinction matters when regulators start asking tough questions.Why Costa Rica Won’t Shut It Down
You might wonder: why hasn’t the government cracked down? Simple - the economy needs it. Costa Rica has no oil. No major manufacturing. Its biggest exports are coffee, pineapples, and tech talent. Crypto startups bring foreign investment, high-skilled jobs, and digital infrastructure. They pay local rent, hire developers, and spend money in the local economy. The government knows this. They also know that if they make rules too strict, these companies will leave for Panama, Uruguay, or even Dubai. So they walk a tightrope: enforce AML rules to satisfy international pressure, but avoid creating barriers that scare away innovation. It’s not a strategy. It’s survival.
What Should You Do If You’re Starting a Crypto Business Here?
If you’re thinking of launching a crypto service in Costa Rica in 2025, here’s what you need to do:- Register your company with the National Registry. Get a legal address. Get a tax ID.
- Apply for SUGEF registration as a VASP. Don’t wait until they force you. Get ahead of the curve.
- Build a full AML/CFT program - even if you’re small. Document everything: customer onboarding, transaction monitoring, risk scoring.
- Use a crypto-friendly bank or partner with a payment processor that handles high-risk clients. Don’t rely on local banks.
- Consult a local lawyer who understands both financial regulation and crypto. Don’t trust generic advice from online forums.
The Future: Gray to Green?
Costa Rica isn’t going to ban crypto. It’s too valuable. But it’s also not going to let the wild west continue forever. The next step? A formal licensing system - but one designed to be light, fast, and affordable. Think Singapore’s approach, not New York’s. The goal isn’t to control crypto. It’s to manage the risks without killing the industry. For now, Costa Rica remains the most attractive jurisdiction in Central America for crypto entrepreneurs. But the window is closing. The rules are changing. The gray area is turning into a corridor - and you need to know which way it’s going before you step inside.Is it legal to buy and hold Bitcoin in Costa Rica?
Yes. Individuals can buy, hold, and trade Bitcoin and other cryptocurrencies without any legal restrictions. The Central Bank clarified in 2017 that private transactions using crypto are permitted, even though they aren’t considered legal tender. You won’t face penalties for owning crypto - only for using it in illegal activities like money laundering.
Do I need a license to run a crypto exchange in Costa Rica?
Not yet - but you must register with SUGEF as a Virtual Asset Service Provider (VASP) under the new 2025 legislation. Registration isn’t a license. It’s compliance. You’re not being approved to operate; you’re being monitored to prevent money laundering. Failing to register could lead to fines or criminal liability if your platform is used for illicit activity.
Can I open a bank account for my crypto business in Costa Rica?
It’s extremely difficult. Most traditional banks in Costa Rica refuse to work with crypto businesses due to perceived risk. Some fintechs and offshore banking partners accept them, but expect higher fees, stricter documentation, and longer approval times. You’ll need a registered company, a detailed AML policy, and often a third-party compliance audit to even get a meeting with a bank.
Are crypto profits taxed in Costa Rica?
Currently, there’s no specific tax on capital gains from cryptocurrency trading for individuals or foreign companies. Costa Rica doesn’t tax foreign-sourced income, which makes it attractive for international crypto entrepreneurs. However, if you’re a resident earning income from crypto services, you may be subject to income tax. Always consult a local tax advisor - rules can change quickly.
What happens if I don’t register as a VASP?
If you’re operating a crypto exchange, custody service, or similar business and don’t register, you’re not breaking the law - yet. But if your platform is linked to money laundering or terrorist financing, you could face criminal charges under existing AML laws. SUGEF can freeze assets, shut down operations, and refer cases to prosecutors. Registration is your best defense against future legal trouble.
Is Costa Rica becoming a crypto hub like Switzerland or Singapore?
Not yet - but it’s on the path. Unlike Switzerland or Singapore, Costa Rica doesn’t offer formal crypto licenses or clear legal status. But it does offer speed, low cost, and political stability. Many businesses use it as a stepping stone - setting up operations here while waiting for clearer regulations elsewhere. It’s a temporary advantage, not a permanent home.
If you’re considering moving your crypto business to Costa Rica, act now - but don’t act blindly. The gray area is still open, but the lights are turning on. The next 12 months will determine whether this becomes a regulated market or a cautionary tale.
