Costa Rica (CR)
Lead Signal
Costa Rica enters World Payments Monitor coverage this cycle with a first full baseline across the module spine, and the standout thread is a status correction on virtual-asset regulation. Amendment No. 25.340 to Law 7786, which adds a new Article 15 quater bringing virtual asset service providers into Costa Rica's AML/CFT framework with mandatory SUGEF registration, passed the Legislative Assembly unanimously on 27 May 2026. As of late June 2026 it awaits presidential signature and publication in La Gaceta and has not been enacted; the registration it establishes is explicitly not an operating licence. The reform is understood to be driven primarily by the need to close that Recommendation 15 gap rather than to build a fintech-specific licensing policy. Recommendation 15, covering new technologies and virtual asset service providers, was downgraded from Compliant to Non-Compliant because Costa Rica lacked a risk-based approach or a supervisory entity for virtual asset service providers. Costa Rica remains in GAFILAT's enhanced follow-up process stemming from its 2015 mutual evaluation. That narrow AML/CFT fix sits inside a wider structural gap: Costa Rica has no dedicated EMI, PSP or money-transmitter licensing statute. Banks and non-bank payment providers fall under the general SUGEF/CONASSIF perimeter under Law 7558 and Law 7732, with non-bank intermediation captured only through the AML/CFT registration route added to Article 15 bis of Law 7558 in 2020. A standalone Fintech Framework Bill, introduced in July 2024 and unanimously approved by a legislative committee in April 2025, has sat without further reported progress for more than fourteen months. Across W1a, W2 and W11 the pattern is consistent: narrow compliance gaps close under external pressure while the broader licensing architecture stays unresolved.
Outlook
The marker to watch is whether Amendment No. 25.340 receives presidential signature and La Gaceta publication, converting the VASP registration route from a passed-but-dormant reform into an operative deadline for virtual asset service providers serving Costa Rican residents. The Visa/Mastercard fee-cap litigation and the parallel legislative effort to curtail the BCCR's cross-border authority remain the highest-impact contested threads, carrying regional precedent value. On the consumer side, the trajectory of SINPE Móvil fraud losses against a judiciary averaging four-year case timelines suggests reimbursement and liability-allocation questions are likely to sharpen rather than resolve unassisted. The Fintech Framework Bill's fourteen-month stall since committee approval remains a standing gap: absent that statute, Costa Rica's non-bank payments sector continues to operate through an AML/CFT-registration lens rather than a dedicated licensing regime, a condition this monitor will continue to track as the baseline position for the jurisdiction.
Other Developments
Visa and Mastercard remain in active litigation against the Banco Central de Costa Rica over the interchange and merchant-discount-rate caps imposed under Law 9831, which they call price controls that improperly reach transactions involving parties outside Costa Rica; Mastercard has stated Costa Rica is the only country imposing such unilateral measures. A parallel legislative bill would strip the BCCR's authority over cross-border card fees, opposed by the BCCR president on the grounds that removing the caps would carry an economic impact comparable to the VAT. The domestic acquiring cap sits at 1.95% and the interchange cap at 2.0%, both tightened since a November 2020 introduction of 2.0%/2.5% ceilings through mandatory annual reviews, with separate and historically higher cross-border caps under a distinct statutory provision. SINPE Móvil, the instant-payment rail that reached over 76% active adult adoption by end-2024 (up from 52% two years earlier) across 44 participating entities including nine non-bank PSPs, has become the dominant surface for social-engineering fraud. Complaints totalled 25,498 between January 2025 and March 2026, with reported instant-transfer fraud losses near ₡3 billion, up roughly 88% year-on-year, driven by a SIM-recycling scam known as "Sinpe mediante comando PASE" and a newly prevalent WhatsApp verification-code takeover technique. Enforcement lags: judiciary data shows only 85 cyber-fraud trials in 2024, producing 44 acquittals against 41 convictions, mostly suspended, with average criminal process length exceeding four years. No mandatory authorised-push-payment reimbursement scheme comparable to the UK's PSR model was identified in force. Costa Rica's banking sector remains highly concentrated, with the top five banks holding roughly 80% of assets and the two state-owned majors alone accounting for 44%. Consolidation continued as Davivienda Group completed its acquisition of Scotiabank's Costa Rica, Colombia and Panama operations, closing 1 December 2025 with the operational switch effective two days later. A smaller nearshore technology deal, Improving's acquisition of Oceans Code Experts, was the other clear Costa Rica-specific commercial event in-window, with deal value undisclosed in both transactions.
Cross-Monitor Connections
Two items are flagged onward to the Financial Intelligence Monitor rather than analysed here as illicit-finance conclusions. The VASP registration reform and the Recommendation 15 downgrade raise supervisory-gap questions for illicit-finance oversight outside WPM's payments-instrument remit; the underlying W11 findings are Sentinel.gi-fed provenance rather than original illicit-finance analysis. Separately, correspondent-banking de-risking pressure tied to cartel terrorist-organisation designations across Latin America, where a BIS Quarterly Review study found roughly a 30% decline in active correspondent-banking activity in the region between 2011 and 2018, carries AML and sanctions dimensions beyond WPM's settlement-access scope. No acute Costa Rica-specific de-risking event was identified this cycle; all Costa Rican commercial banks continue to maintain correspondent relationships with major U.S. banks.
Legal accessibility by product
overall:Domains
14 regulatory modules · click to expand the full sub-briefLicensing, Authorisation & Market Access
HighCosta Rica has no dedicated EMI, PSP or money-transmitter licensing statute; banks and non-bank payment providers alike fall under the general SUGEF/CONASSIF supervisory perimeter established by Law 7558 and Law 7732, with non-bank financial intermediation captured via Article 15 bis of Law 7558 since a 2020 reform.
Conduct, Safeguarding & Promotions
HighState-owned banks in Costa Rica carry a full sovereign deposit guarantee via the Central Bank, while private-bank deposit protection is a distinct, less-standardised scheme under the Deposit Guarantee Fund Law No. 9816.
Operational Resilience & Critical Infrastructure
HighBeginning 17 April 2022, a Conti/Hive ransomware attack hit nearly 30 Costa Rican government institutions, including the Ministry of Finance and the state Social Security Fund, prompting a declared state of emergency.
Scheme & Network Compliance
HighUnder Legislative Decree/Law No.
Payment Corridor Dynamics
HighThe cost of sending money from Costa Rica to Nicaragua doubled from about 3% in 2015Q4 to more than 6% in 2023Q1, a steeper trajectory than the regional Latin America average of 5.8%.
Full per-domain detail — all 14 modules
Costa Rica has no dedicated EMI/PSP/MTL licensing statute. Banks and non-bank PSPs alike fall under the general supervisory perimeter of SUGEF/CONASSIF (Law 7558, Law 7732), with non-bank financial intermediation captured via Article 15 bis of Law 7558 since a 2020 reform. A standalone Fintech Framework Bill has been under legislative review since mid-2024 but is not yet enacted.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Licensing, Authorisation & Market Access
Costa Rica has no dedicated EMI, PSP or money-transmitter licensing statute; banks and non-bank payment providers alike fall under the general SUGEF/CONASSIF supervisory perimeter established by Law 7558 and Law 7732, with non-bank financial intermediation captured via Article 15 bis of Law 7558 since a 2020 reform. A standalone Fintech Framework Bill, introduced on 9 July 2024 by congresswoman Monserrat Ruiz Guevara, obtained unanimous approval from the Permanent Ordinary Committee on Economic Affairs on 29 April 2025, but as of July 2026 — more than fourteen months later — remains pending enactment with no further reported legislative progress. SUGEF is reported to assert that its licensing and oversight scope reaches foreign payment service providers without local physical presence that service Costa Rican residents, requiring SUGEF authorisation notwithstanding the absence of a formal EMI-equivalent licence class; this single-source claim is flagged for further corroboration.
Outlook
The near-term marker is whether the Fintech Framework Bill moves beyond committee approval; absent that statute, Costa Rica's non-bank payments sector will continue to operate through an AML/CFT-registration lens rather than a dedicated licensing regime, leaving both domestic and cross-border PSPs without a codified authorisation pathway.
Costa Rica has no dedicated EMI/PSP/MTL licensing statute. Banks and non-bank PSPs alike fall under the general supervisory perimeter of SUGEF/CONASSIF (Law 7558, Law 7732), with non-bank financial intermediation captured via Article 15 bis of Law 7558 since a 2020 reform. A standalone Fintech Framework Bill has been under legislative review since mid-2024 but is not yet enacted.
Evidence — 5 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Fintech in Costa Rica: Legal Perspective and Regulation [T3] Superintendencia General de Entidades Financieras (Costa Rica): Licensing, Oversight & Scope | PayAtlas [T3]
Consumer/depositor protection rests on the Deposit Guarantee Fund Law (No. 9816) for private banks, SUGEF's disclosure/advertising regulation (SUGEF 10-07), and general consumer-protection law administered via the National Consumer Commission. State-owned banks carry a full sovereign deposit guarantee; private-bank protection is a distinct, less-standardised scheme.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Conduct, Safeguarding & Financial Promotions
State-owned banks in Costa Rica carry a full sovereign deposit guarantee via the Central Bank, while private-bank deposit protection is a distinct, less-standardised scheme under the Deposit Guarantee Fund Law No. 9816. Conduct and financial-promotions rules run through SUGEF 10-07 (the Regulation on Disclosure of Information and Advertising of Financial Products and Services), alongside CONASSIF 4-16 on corporate governance and CONASSIF 6-18 on financial information. The World Bank's Costa Rica Financial Sector Assessment recommends that authorities establish a strong financial-consumer-protection framework based on a clear institutional mandate and dedicated resources, implying the current mandate is fragmented rather than centrally vested.
Outlook
The clearest gap is institutional rather than statutory: without a centrally vested consumer-protection mandate, conduct rules under SUGEF 10-07 and the CONASSIF governance/disclosure stack risk uneven enforcement, particularly given the bifurcated state-versus-private deposit guarantee structure.
Consumer/depositor protection rests on the Deposit Guarantee Fund Law (No. 9816) for private banks, SUGEF's disclosure/advertising regulation (SUGEF 10-07), and general consumer-protection law administered via the National Consumer Commission. State-owned banks carry a full sovereign deposit guarantee; private-bank protection is a distinct, less-standardised scheme.
Evidence — 4 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Costa Rica - Banking - Expat Focus [T3] Banking Regulation 2025 - Costa Rica | Global Practice Guides | Chambers and Partners [T3] FOR OFFICIAL USE ONLY COSTA RICA FINANCIAL SECTOR ASSESSMENT Prepared By [T1]
Costa Rica has no stablecoin-specific or comprehensive VASP licensing law in force. The BCCR does not treat cryptoassets as legal tender but does not prohibit private use. A VASP AML/CFT registration reform (building on Bill 22.837) has been reported as enacted around May 2026, requiring SUGEF registration for AML/CFT supervisory purposes only — explicitly not an operating licence. A BCCR digital-colón CBDC initiative remains at the research stage since 2021 with no pilot launched.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Stablecoins & Digital Money
Amendment No. 25.340 to Law 7786, adding Article 15 quater and formally bringing virtual asset service providers into Costa Rica's AML/CFT framework with mandatory SUGEF registration, was passed unanimously by the Legislative Assembly on 27 May 2026. As of late June 2026 it awaits presidential signature and publication in La Gaceta and has not been enacted; the registration is explicitly not an operating licence. SUGEF's registration/deregistration regime under Articles 15 and 15-bis of Law 7786 exists for AML/CFT purposes only and creates no general VASP authorisation; token issuance, custody rules and exchange licensing remain unregulated. The BCCR's digital-colón CBDC initiative, announced in 2021, remains recorded as "Research" status with no pilot or wholesale programme launched.
Outlook
The marker to track is enactment: presidential signature and La Gaceta publication would convert Amendment No. 25.340 from a passed-but-dormant reform into a live SUGEF registration deadline for virtual asset service providers, though even then it would remain an AML/CFT registration rather than a comprehensive VASP licensing regime, leaving token issuance, custody and exchange activity unregulated.
Costa Rica has no stablecoin-specific or comprehensive VASP licensing law in force. The BCCR does not treat cryptoassets as legal tender but does not prohibit private use. A VASP AML/CFT registration reform (building on Bill 22.837) has been reported as enacted around May 2026, requiring SUGEF registration for AML/CFT supervisory purposes only — explicitly not an operating licence. A BCCR digital-colón CBDC initiative remains at the research stage since 2021 with no pilot launched.
Evidence — 6 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
VASP Regulation Costa Rica [T3] Crypto License in Costa Rica | Crypto Company Setup & Compliance [T3] Costa Rica CBDC (Costa Rica) Digital Currency | CBDC Tracker [T3]
W3HighOperational Resilience & Critical Infrastructure
see this theme across all jurisdictions →4 claimsCosta Rica's operational-resilience posture was shaped decisively by the April 2022 Conti/Hive ransomware campaign against government systems, which triggered a national state of emergency. IT/outsourcing risk management for the regulated financial sector sits under CONASSIF 5-17, complemented by a 2023-2027 national cybersecurity strategy backed by US government support for a national SOC.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Operational Resilience & Critical Infrastructure
Beginning 17 April 2022, a Conti/Hive ransomware attack hit nearly 30 Costa Rican government institutions, including the Ministry of Finance and the state Social Security Fund, prompting a declared state of emergency. CONASSIF 5-17, the Regulation of Information Technology Management, is the operative IT and operational-resilience regulation applicable to SUGEF-supervised financial entities, alongside CONASSIF 16-22 on consolidated supervision. Following the 2022 attack, Costa Rica released a 2023-2027 national cybersecurity strategy including mandatory cybersecurity personnel in every government ministry, with the U.S. State Department committing $25 million to build a national Security Operations Center.
Outlook
Costa Rica's 2023-2027 cybersecurity strategy runs through end-2027 with continued U.S. backing, giving the sector a defined multi-year horizon for the national Security Operations Center build-out even as CONASSIF 5-17 keeps IT-outsourcing risk under standard prudential supervision rather than a bespoke resilience regime.
Costa Rica's operational-resilience posture was shaped decisively by the April 2022 Conti/Hive ransomware campaign against government systems, which triggered a national state of emergency. IT/outsourcing risk management for the regulated financial sector sits under CONASSIF 5-17, complemented by a 2023-2027 national cybersecurity strategy backed by US government support for a national SOC.
Evidence — 4 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
2022 Costa Rican ransomware attack - Wikipedia [T3] Banking Regulation 2025 - Costa Rica | Global Practice Guides | Chambers and Partners [T3] S02 E07: Costa Rican Cybersecurity Policy with Minister Paula Bogantes [T3]
Costa Rica is the only known jurisdiction to impose central-bank price controls on both merchant discount rates and interchange/interchange-reimbursement fees for card schemes, under Legislative Decree 9831 (2020), implemented and progressively tightened by BCCR through annual ordinary reviews. This regime is currently the subject of active litigation from Visa and Mastercard (see W7).
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Scheme & Network Compliance
Under Legislative Decree/Law No. 9831 (2020), the BCCR sets maximum acquisition and interchange reimbursement fees for card schemes; the domestic acquiring cap sits at 1.95% and interchange at 2.0%, with separate and historically higher cross-border caps under Article 46. Costa Rica is described as the only known jurisdiction imposing central-bank price controls on both merchant discount rates and interchange fees. Starting 24 November 2020, the BCCR set maximum interchange fees for domestic cards at 2.0% and maximum MDR at 2.5%, and has gradually ratcheted down both caps over a four-year period through mandatory annual ordinary reviews.
Outlook
The annual-review mechanism means further downward pressure on both caps is likely absent a change in law, but the outcome of the Visa/Mastercard litigation and the parallel legislative bill to strip BCCR's cross-border authority will determine whether the current dual-price-control structure survives in its present form.
Costa Rica is the only known jurisdiction to impose central-bank price controls on both merchant discount rates and interchange/interchange-reimbursement fees for card schemes, under Legislative Decree 9831 (2020), implemented and progressively tightened by BCCR through annual ordinary reviews. This regime is currently the subject of active litigation from Visa and Mastercard (see W7).
Evidence — 5 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Reglamento del Sistema de Tarjetas de Pago [T3] What the IMF Gets Wrong About Costa Rica's Payment-Card Caps - Truth on the Market [T3]
Costa Rica's principal cross-border payment corridors are outbound remittances to Nicaragua and inbound remittances from the United States, both intermediated primarily through banks/MTOs and correspondent banking/SWIFT rather than any regional instant-payment linkage. Domestically, SINPE and SINPE Móvil dominate retail rails; SINPE-TP extends contactless rails into public transport.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Payment Corridor Dynamics
The cost of sending money from Costa Rica to Nicaragua doubled from about 3% in 2015Q4 to more than 6% in 2023Q1, a steeper trajectory than the regional Latin America average of 5.8%. The World Bank Remittance Prices Worldwide database tracks the US-to-Costa Rica corridor with typical costs in the 1.8-2.1% range at the $200-$500 send-value tier, materially cheaper than the CR-Nicaragua corridor. Bank letters of credit remain the most common and secure trade-payment method, and the free convertibility of the colón alongside the absence of remittance controls encourages open-account relationships where credit risk is minimal.
Outlook
The CR-Nicaragua corridor's deteriorating cost trajectory sits outside the scope of any regional instant-payment linkage, and coverage of Central American rails beyond that single corridor remains thin, so continued monitoring should widen to Panama and Honduras exposure as data becomes available, while the low-cost US-CR corridor and bank-intermediated trade finance remain structurally stable.
Costa Rica's principal cross-border payment corridors are outbound remittances to Nicaragua and inbound remittances from the United States, both intermediated primarily through banks/MTOs and correspondent banking/SWIFT rather than any regional instant-payment linkage. Domestically, SINPE and SINPE Móvil dominate retail rails; SINPE-TP extends contactless rails into public transport.
Evidence — 4 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Remittances to Latin America still growing [T1] Sending money from United States to Costa Rica [T1] Costa Rica - Trade Financing [T1]
Costa Rica's banking sector is highly concentrated (top-5 banks ~80% of assets), led by two state-owned banks holding 44% of assets, alongside foreign-owned private banks (BAC Credomatic/Grupo Aval, Scotiabank transitioning to Davivienda). A growing but still-fragmented non-bank fintech sector (estimated 45-120 firms) operates without a dedicated licensing regime, and no BigTech currently operates domestically.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Industry Structure & Commercial Dynamics
Bank-asset concentration among the largest five banks in Costa Rica stands at 80%; the two largest, state-owned Banco de Costa Rica and Banco Nacional de Costa Rica, together account for 44% of total banking-sector assets. The World Bank counts approximately 45 fintech entities, mostly specialised in payments and transfers, while The Fintech Times' 2026 estimate places the figure as high as 120 firms across payments, lending, wealthtech and insurtech, with no BigTech currently operating domestically. Davivienda Group completed its acquisition of Scotiabank's Costa Rica, Colombia and Panama banking operations under an agreement announced 6 January 2025; final regulatory approvals were received 24 November 2025 and the transaction closed 1 December 2025, with the operational switch to Davivienda Group effective 3 December 2025.
Outlook
The Davivienda-Scotiabank transfer reduces the count of independent foreign-bank groups in an already-concentrated market and consolidates Colombian banking-group presence across Central America, while the fintech-sector size estimate remains uncertain between roughly 45 and 120 firms; that divergence, plus the sector's continued dependence on third-party processing infrastructure such as EVERTEC, is worth tracking as consolidation proceeds.
Costa Rica's banking sector is highly concentrated (top-5 banks ~80% of assets), led by two state-owned banks holding 44% of assets, alongside foreign-owned private banks (BAC Credomatic/Grupo Aval, Scotiabank transitioning to Davivienda). A growing but still-fragmented non-bank fintech sector (estimated 45-120 firms) operates without a dedicated licensing regime, and no BigTech currently operates domestically.
Evidence — 5 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
FOR OFFICIAL USE ONLY COSTA RICA FINANCIAL SECTOR ASSESSMENT Prepared By [T1] Scotiabank and Davivienda Close Previously Announced Transaction [T2] EVERTEC, Inc. [T3]
The dominant live payments litigation in Costa Rica is the Visa/Mastercard challenge to the BCCR's interchange/MDR fee-cap regime under Law 9831, contesting the central bank's jurisdiction over cross-border card transactions. A parallel legislative effort to strip the BCCR of authority over cross-border fees is opposed by the BCCR president.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Legal & Litigation
Visa and Mastercard argue that Law 9831 grants the BCCR authority only over domestic transactions and that its regulations impermissibly extend to participants located outside Costa Rica, calling the caps a form of "price control"; Mastercard has stated that Costa Rica is the only country imposing such unilateral measures. A bill under review in the Legislative Assembly aims to remove the BCCR's authority to regulate cross-border card transactions and is supported by Visa and Mastercard, but opposed by the BCCR president, who argues eliminating the caps would have an economic impact comparable to the VAT. Judiciary data shows only 85 cyber-fraud trials in 2024, with 44 acquittals and 41 convictions, mostly suspended sentences, and an average total criminal-process time of over four years, despite a surge in complaints.
Outlook
The Visa/Mastercard litigation and the parallel legislative bill are the two forks of the same dispute over the BCCR's cross-border fee-cap authority, and their resolution will also shape whether Costa Rica's low cyber-fraud conviction rate becomes a secondary pressure point in scheme-compliance discussions, given how enforcement outcomes intersect with consumer-facing fraud losses tracked under W10.
The dominant live payments litigation in Costa Rica is the Visa/Mastercard challenge to the BCCR's interchange/MDR fee-cap regime under Law 9831, contesting the central bank's jurisdiction over cross-border card transactions. A parallel legislative effort to strip the BCCR of authority over cross-border fees is opposed by the BCCR president.
Evidence — 4 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Visa and Mastercard Sue Costa Rica's Central Bank Over Fee Caps : The Tico Times | Costa Rica News | Travel | Real Estate [T3] Cybercriminal “businesses” plague Costa Rica: scams grew 668% in 4 years with just a handful of convictions | Q COSTA RICA [T3]
Merchant acquiring in Costa Rica operates through bank-affiliated gateways subject to SUGEF oversight, with acquiring/interchange fees capped by BCCR regulation. Riskier or ecommerce-ineligible merchant categories face ad hoc bank-level rejection rather than a codified high-risk-MCC framework, and select MCCs (fuel, EV charging, tolls, regulated transport, charities) are carved out of the standard acquiring fee cap.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Merchant Acquiring & Risk
Payment gateways in Costa Rica are not banks; they operate in conjunction with an acquiring bank and, subject to SUGEF oversight, have permission only to process collections, while only the bank can approve or reject the final transaction, often without disclosing rejection reasons. The domestic maximum acquiring commission of 1.95% carries explicit carve-out exceptions for service stations, electric-vehicle charging services, tolls, ARESEP-regulated transport services, and charitable organisations.
Outlook
Absent a codified high-risk-MCC framework, merchant decline decisions in Costa Rica will likely continue to be made ad hoc at the acquiring-bank level rather than through a transparent, gateway-level risk policy, even as select public-interest categories keep their carve-out protection from the standard acquiring cap.
Merchant acquiring in Costa Rica operates through bank-affiliated gateways subject to SUGEF oversight, with acquiring/interchange fees capped by BCCR regulation. Riskier or ecommerce-ineligible merchant categories face ad hoc bank-level rejection rather than a codified high-risk-MCC framework, and select MCCs (fuel, EV charging, tolls, regulated transport, charities) are carved out of the standard acquiring fee cap.
Evidence — 3 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Online payment processing in Costa Rica: what small business owners need to know – El Colectivo 506 [T3] Reglamento del Sistema de Tarjetas de Pago [T3]
SINPE Móvil is Costa Rica's flagship retail payment innovation, achieving near-universal adult engagement since its 2015 launch, alongside a 2015-era EMV/contactless migration mandate and the SINPE-TP transit-payment rollout. CBDC work remains at research stage; open banking/open-finance rulemaking is under discussion but not yet formalised; institutional Bitcoin ETF access entered the banking system in 2025.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Product Innovation & Market Development
By end-2024 over 76% of the population older than 15 were active SINPE Móvil users, up from 52% at end-2022; the service accounts for close to 80% of interbank transfer volume though only 4% by value, across 44 participating entities of which 9 are non-bank PSPs. SINPE-TP, the National Electronic Payment System for Public Transport, launched in 2020 after a six-month pilot with the state railway institute INCOFER, following BCCR guidelines for modernising public-sector collection and payment mechanisms issued in June 2019. Regulatory discussions have advanced around open banking and data-sharing protocols in Costa Rica, but formal open-banking frameworks remain evolving and not yet in force, with no consultation timeline identified. Bitcoin ETFs were adopted by local Costa Rican banks in 2025, a single-source signal flagged for corroboration, but one pointing to increased institutional acceptance and a possible future link between traditional banking and digital-asset products.
Outlook
SINPE Móvil's near-universal reach makes it the base layer for whatever open-banking or data-sharing framework eventually formalises, while the still-uncertain regulatory status of institutional Bitcoin ETF access signals that product innovation is currently outpacing the formal rulemaking needed to govern it, a gap this monitor will track pending any published consultation timeline.
SINPE Móvil is Costa Rica's flagship retail payment innovation, achieving near-universal adult engagement since its 2015 launch, alongside a 2015-era EMV/contactless migration mandate and the SINPE-TP transit-payment rollout. CBDC work remains at research stage; open banking/open-finance rulemaking is under discussion but not yet formalised; institutional Bitcoin ETF access entered the banking system in 2025.
Evidence — 6 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Fast payments and banking: Costa Rica's SINPE Móvil [T1] Costa Rica launched national electronic payment system for public transportation - Mobility Innovators [T3] The Fintech Landscape of Central America: Costa Rica in 2026 | The Fintech Times [T3] Costa Rica's Crypto Market to Reach $20.3 Million by 2025 [T3]
SINPE Móvil-linked social-engineering fraud (SIM/phone-recycling scams and WhatsApp verification-code takeovers) is the dominant consumer-facing payments-fraud vector, with rapidly rising complaint volumes and losses but low criminal conviction rates. No mandatory APP-fraud reimbursement scheme comparable to the UK PSR model was identified in force.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Consumer Protection & APP Fraud
A SIM-recycling scam known as "Sinpe mediante comando PASE" and a newly prevalent WhatsApp verification-code takeover scam are driving fraud growth: 25,498 fraud complaints were recorded between 1 January 2025 and 30 March 2026, with reported instant-transfer fraud losses near ₡3 billion, up about 88% year-on-year. Financial consumer protection rules derive from the Law on the Promotion of Competition and Effective Consumer Defense and National Consumer Commission provisions, which apply generally to contractual terms and consumer protection but are not payments-fraud-reimbursement specific; no mandatory APP-fraud reimbursement scheme comparable to the UK PSR model was identified in force.
Outlook
With SINPE Móvil fraud losses up roughly 88% year-on-year against a criminal-justice system averaging four-year case timelines and a conviction rate too thin to deter, the absence of a mandatory authorised-push-payment reimbursement scheme is the clearest structural gap in Costa Rica's consumer-protection architecture, and one likely to draw increasing attention as complaint volumes keep climbing.
SINPE Móvil-linked social-engineering fraud (SIM/phone-recycling scams and WhatsApp verification-code takeovers) is the dominant consumer-facing payments-fraud vector, with rapidly rising complaint volumes and losses but low criminal conviction rates. No mandatory APP-fraud reimbursement scheme comparable to the UK PSR model was identified in force.
Evidence — 5 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Costa Rica Sees Ongoing Spike in Digital Fraud Tied to Travel and Payments : The Tico Times | Costa Rica News | Travel | Real Estate [T3] Fintech in Costa Rica: Legal Perspective and Regulation [T3]
W11HighAML/CFT & Financial Crime (Sentinel.gi-fed)
Sentinelsee this theme across all jurisdictions →7 claimsCosta Rica remains in GAFILAT's enhanced follow-up process from its 2015 Mutual Evaluation, with its most significant outstanding technical gap being VASP supervision (Recommendation 15, downgraded to Non-Compliant). The core AML/CFT legal architecture is Law 8204/7786, supervised jointly by SUGEF/CONASSIF and the ICD's Financial Intelligence Unit.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
AML/CFT & Financial Crime
The following intelligence on Costa Rica's AML/CFT posture is sourced from the Sentinel.gi feed and is carried here as cross-referenced provenance rather than original illicit-finance analysis; readers should consult Sentinel.gi directly for the underlying investigative detail. Recommendation 15 (New Technologies/VASPs) was downgraded from Compliant to Non-Compliant because Costa Rica lacked a risk-based approach or a supervisory/oversight entity for virtual asset service providers at the time of the relevant re-rating analysis. Costa Rica remains in GAFILAT's enhanced follow-up process from its 2015 Mutual Evaluation, with core AML/CFT legal architecture under Law 8204/7786, supervised jointly by SUGEF/CONASSIF and the ICD's Financial Intelligence Unit per SUGEF 13-19 and SUGEF 12-21. A VASP registration reform bringing virtual asset service providers into scope as AML/CFT obligated subjects, requiring mandatory SUGEF registration, is driven primarily by the need to close the FATF Recommendation 15 gap rather than to establish a fintech-specific licensing policy. Consistent with the parallel W2 correction, this reform passed the Legislative Assembly on 27 May 2026 but is not yet enacted, pending presidential signature and La Gaceta publication.
Outlook
Costa Rica's Recommendation 15 rating is unlikely to improve until the VASP registration reform is actually enacted rather than merely passed, so the enactment date — not the 27 May 2026 legislative vote — is the marker Sentinel.gi and this monitor will jointly track, alongside continued observation of Costa Rica's standing in GAFILAT's enhanced follow-up process.
Costa Rica remains in GAFILAT's enhanced follow-up process from its 2015 Mutual Evaluation, with its most significant outstanding technical gap being VASP supervision (Recommendation 15, downgraded to Non-Compliant). The core AML/CFT legal architecture is Law 8204/7786, supervised jointly by SUGEF/CONASSIF and the ICD's Financial Intelligence Unit.
Evidence — 7 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- True
Event Findings
Sources
GAFILAT-Costa-Rica-Follow-Up-Report-2023. ... [T1] VASP Regulation Costa Rica [T3]
All Costa Rican commercial banks maintain correspondent relationships with major U.S. banks, and no acute de-risking event specific to Costa Rica was identified, though the jurisdiction sits within a Latin American region subject to generalised correspondent-banking contraction pressure tied to AML/CFT compliance costs and, more recently, cartel-related U.S. designations.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Correspondent Banking, Settlement & Access
The structural spine of Costa Rica's correspondent-banking position is the asymmetry between banks, which hold established U.S. correspondent relationships, and non-bank payment institutions, which have no equivalent direct settlement access and depend on sponsor-bank arrangements. All commercial banks in Costa Rica maintain correspondent relationships with major U.S. banks, and SUGEF publishes a full list of each supervised entity's correspondent relationships; no acute Costa Rica-specific de-risking event was identified. Major U.S. dollar clearing banks may view providing correspondent banking services to Latin American banks with extensive Central American operations as presenting new and additional risk following cartel terrorist-organisation designations; a BIS Quarterly Review study found an approximately 30% decline in active correspondent banking activity in Latin America between 2011 and 2018.
Outlook
No acute Costa Rica-specific de-risking event has materialised, but the regional correspondent-banking contraction — and the newer cartel-designation dimension flagged onward to the Financial Intelligence Monitor — means the bank-versus-non-bank access asymmetry underlying W12 is a structural condition worth continued monitoring rather than a settled one.
All Costa Rican commercial banks maintain correspondent relationships with major U.S. banks, and no acute de-risking event specific to Costa Rica was identified, though the jurisdiction sits within a Latin American region subject to generalised correspondent-banking contraction pressure tied to AML/CFT compliance costs and, more recently, cartel-related U.S. designations.
Evidence — 4 structured claims
Key facts
- Content Tier
- SB
- Sentinel Feed
- False
Event Findings
Sources
Costa Rica - U.S. Banks and Local Correspondent Banks | Privacy Shield [T1] Correspondent Banking-Related Risks Arising from Cartels’ Designations as Terrorist Organizations | Covington & Burling LLP [T3]
W13AssessedCommercial Intelligence (M&A, Investment & Product)
see this theme across all jurisdictions →2 claimsCosta Rica-specific commercial activity in the trailing 12 months is comparatively thin relative to processor-level regional M&A (e.g., Evertec's broader Latin American acquisition programme); the clearest Costa Rica-specific event in-window is a nearshore technology-services acquisition. Deal value for that transaction is undisclosed.
No periodic updates yet · baseline brief is current.
Read the full sub-brief
Commercial Intelligence (M&A, Investment & Product)
Scotiabank's Colombia, Costa Rica and Panama banking operations were transferred to Davivienda Group; the transaction closed 1 December 2025 with the operational switch effective 3 December 2025, and deal value was not publicly disclosed. IT consulting firm Improving expanded its Costa Rica presence by acquiring Oceans Code Experts, a nearshore technology-services provider, strengthening delivery capabilities across Latin America; deal value not publicly disclosed.
Outlook
Costa Rica-specific commercial-event coverage this cycle is thin relative to processor-level regional M&A; both in-window deals carry undisclosed values, and the more consequential commercial signal for the jurisdiction remains the structural W6 concentration effect of the Davivienda-Scotiabank transfer rather than any single new transaction.
Costa Rica-specific commercial activity in the trailing 12 months is comparatively thin relative to processor-level regional M&A (e.g., Evertec's broader Latin American acquisition programme); the clearest Costa Rica-specific event in-window is a nearshore technology-services acquisition. Deal value for that transaction is undisclosed.
Evidence — 2 structured claims
Key facts
- Content Tier
- D
- Sentinel Feed
- False
Event Findings
Sources
Scotiabank and Davivienda Close Previously Announced Transaction [T2] Evertec Acquires Brazilian Rival Dimensa - Nearshore Americas [T3]