You have to register with SUGEF, Costa Rica’s financial superintendency, if your business works in one of the non-financial activities listed in the country’s anti-money-laundering law. That includes brokering, buying and selling or developing real estate, running a casino, lending money, and handling property sales, client funds or company deals as a lawyer or accountant. You register online through the SUGEF Directo platform with a Costa Rican digital signature, filing sworn statements about your owners, criminal records, compliance manual, source of funds and dedicated bank accounts. SUGEF has 40 calendar days to decide, or up to 60 for complex cases. Buying or selling a home for yourself does not require registration.
Registration is not a license. It puts your business under SUGEF’s anti-money-laundering supervision, and banks can’t serve a business in a covered activity until it is registered.
| The law | Law 7786, articles 15 and 15 bis, plus article 15 quater for crypto service providers |
|---|---|
| The rules | Acuerdo SUGEF 11-18 (registration) and Acuerdo SUGEF 13-19 (obligations after you register) |
| Who registers | Real estate brokers, developers and dealers; casinos; lenders; pawnshops; trust service providers; dealers in precious metals and stones; lawyers and accountants handling certain client transactions; some nonprofits; crypto service providers |
| Who doesn’t | People buying or selling their own property; salaried lawyers and accountants at supervised employers; lenders averaging $5,000 a month or less |
| Where | The IPO registration system on SUGEF Directo |
| You’ll need | A Costa Rican digital signature certificate (firma digital), or a representative who has one |
| Decision time | 40 calendar days, up to 60 for complex cases |
| Cost | An annual supervision fee set by CONASSIF. Liberal professionals are exempt. |
| Reporting threshold | Transactions of $10,000 or more, reported through SUGEF’s SICVECA system |
| Check a business | SUGEF’s registration status lookup |
| Questions | articulo15bis-crm@sugef.fi.cr, or 2243-4848 and 2243-5048, option 2. SICVECA reporting questions go to consultasarticulo15@sugef.fi.cr. |
Who has to register with SUGEF
Article 15 bis of Law 7786 covers individuals and companies in these activities, which regulators call designated non-financial businesses and professions:
- Buying and selling real estate professionally and habitually, and handling property purchases or sales for clients
- Casinos, including online casinos operated from Costa Rica
- Lending money or extending credit in any form while using accounts at supervised financial institutions
- Pawnshops
- Trust service providers, except guarantee, testamentary, custody and asset-holding trusts
- Dealers in precious metals, precious stones and products made with them
- Lawyers, accountants and other people or companies that, for clients, buy or sell property, manage money, bank accounts or other assets, or set up, run, buy or sell companies
- Nonprofits that send money to or receive it from high-risk countries, or have parent or affiliate organizations there
Real estate is the activity most foreign residents run into. It covers brokers, agents, intermediaries and developers, not just companies that trade property on their own account. If you manage rental properties and hold owners’ money in your own accounts, ask a lawyer whether the client-funds rule applies to you.
Notaries fall under the same law but are supervised by a specialized unit of the National Notary Directorate (Dirección Nacional de Notariado) rather than SUGEF. Article 15 covers financial-type businesses such as currency exchange, money transfers, remittances and credit card issuers, and those must register as companies.
Crypto businesses are now covered too. Law 10961, published June 19, 2026, took effect about three months later and requires anyone who exchanges, transfers, holds or administers virtual assets as a business to register with SUGEF. The detailed requirements are set by regulation from CONASSIF, the council that oversees SUGEF, and those rules were still pending when this guide was updated. Check SUGEF for the current crypto registration rules before you file.
Who doesn’t have to register
- People buying a home, lot or condo for themselves, or selling their own property. The rule is aimed at people who deal in property professionally or handle deals for clients. Repeatedly buying and selling similar properties within 12 months, such as flipping, can count as habitual.
- Lawyers and accountants who work as salaried employees of a supervised employer
- Lenders whose transactions averaged $5,000 a month or less over the last 12 months, and solidarity associations that lend only to their own members
If your bank asks whether your business is a regulated subject and it isn’t, the bank may ask for a notarized sworn statement, signed by your legal representative, explaining why the rules don’t apply.
Documents you need for SUGEF registration
Everything is filed electronically as a sworn statement. The full list is in articles 6 and 7 of Acuerdo SUGEF 11-18.
If you register as an individual, you provide:
- Your identification, nationality, country of birth, trade name, address and an email for notifications
- Sworn statements, backed by criminal record certificates, that you have no record for money laundering or financing terrorism
- A sworn statement that you aren’t on United Nations or U.S. Treasury (OFAC) sanctions lists
- Confirmation that you have an anti-money-laundering manual and approved procedures
- Where your working capital comes from, and a detailed description of the activity
- Proof that you’re registered on the UIF Reportes platform of the Costa Rican Drug Institute’s Financial Intelligence Unit
- The IBAN numbers of bank accounts in your name that you use only for the registered activity
If you register a company, the corporate documents cover:
- Legal name, corporate ID number, trade name, address and an email for notifications
- Legal representatives, attorneys-in-fact, board members, the oversight body and the general manager
- Beneficial owners holding 10% or more of the shares, directly or indirectly, backed by a recent notarial shareholder certification or your filing in the Central Bank’s beneficial ownership registry (RTBF)
- Criminal records for representatives, directors, managers and 10% owners, from Costa Rica and from each person’s countries of birth, nationality and residence, plus sanctions-list statements
- A recent certification from the National Registry (Registro Nacional), plus a copy of the legal representative’s ID. Foreign directors and owners who don’t live in Costa Rica can be identified by passport.
- The source of the working capital and share capital, and a description of the activity
- The anti-money-laundering manual, UIF Reportes registration and dedicated IBAN accounts
SUGEF sets maximum ages for certifications, from 15 days to one month depending on the document, so order them shortly before you file. Documents issued abroad must be apostilled or legalized and translated into Spanish. You also need an office in Costa Rica that can be verified, because banks must drop clients whose premises can’t be confirmed.
Companies registering under article 15, and casinos, also need an assurance report from a certified public accountant (contador público autorizado) backing their anti-money-laundering manual.
How to register with SUGEF, step by step
- Get a Costa Rican digital signature. Banks issue the certificate and card at an in-person appointment. You need a Costa Rican cédula, a DIMEX residency card or a DIDI diplomatic ID, and a passport isn’t accepted. If the person who has to sign doesn’t qualify, a company usually files through a legal representative or general attorney recorded in the National Registry who has a digital signature. SUGEF accepts filings through a special power of attorney only in limited cases, so check with SUGEF before you rely on one.
- Register on UIF Reportes. This is the Financial Intelligence Unit’s platform, where suspicious transaction reports go.
- Open a dedicated bank account. You need an account in your name at a supervised bank for each registered activity. The bank can open it but keeps it inactive until you show proof of registration.
- Write your compliance manual. Your anti-money-laundering manual and procedures follow Acuerdo SUGEF 13-19.
- File in SUGEF Directo. Open the IPO registration system and add the legal representative first, because that role has to be active before any other role can be added. Fill in SUGEF’s unified forms and sign them, and your cover letter, with the digital signature.
- Answer any request for missing documents. SUGEF asks once and gives you at least 10 business days. If you don’t fully answer in time, your application is rejected and archived.
- Wait for the decision. SUGEF has 40 calendar days from confirming receipt, or up to 60 for complex cases. Once granted, registration doesn’t expire.
SUGEF publishes PDF and video guides on its help page for registered businesses, including how to register through a power of attorney. The process is in Spanish, so many foreign-run businesses hire a lawyer or accountant to file it.
What you must do after you’re registered
- SUGEF classifies you as Type 1, 2 or 3 by risk. Type 1 businesses must name a compliance officer, and Types 2 and 3 name a liaison. You send categorization information 20 days after the month you register and every April after that.
- Report transactions of $10,000 or more through SICVECA, whether single or combined and whether in cash or not. Some activities have other thresholds.
- Report suspicious transactions to the Financial Intelligence Unit.
- Tell SUGEF about any change in your information within three business days. If you stop the activity, ask to be deregistered within 10 business days.
- Show your registration notice and SUGEF’s required warning at your office, on your website and in your contracts.
- Pay the annual supervision fee, unless you’re exempt as a liberal professional.
- Answer SUGEF’s information requests. Since October 2025, SUGEF has been sending selected businesses an online compliance questionnaire due within 15 business days.
If you don’t supply information SUGEF asks for, or carry out no registered activity for 12 months in a row, SUGEF can suspend your registration after giving you 15 business days to fix the problem. A suspension that isn’t resolved within three months becomes a cancellation, and SUGEF publishes suspensions on its website.
What happens if you don’t register
Banks and other supervised financial institutions can’t provide or keep providing services to a business in a covered activity that isn’t registered. In practice, that means your accounts can be frozen or closed. SUGEF can also order a business to register, and you then have 30 business days to file.
Fines under article 81 of Law 7786 run from two to 100 base salaries for breaches that include refusing to register. Failing to properly record transactions of $10,000 or more can bring fines of 5% to 50% of the amount involved. Fines are due within eight business days, with a 3% monthly surcharge if you pay late.
What SUGEF registration means if you’re buying property
You don’t register as a buyer, but you’ll deal with businesses that do. Expect your broker, lawyer and bank to ask who you are, who owns any corporation you’re buying through and where your money comes from. That’s their legal obligation, not a sign that something is wrong, and it shapes how escrow works in Costa Rica and what your closing process looks like.
Before you choose a real estate broker, check their status on SUGEF’s lookup page. Registered businesses must also display their registration notice on their website and in their contracts, which makes it one of the easiest checks you can do to avoid real estate scams.
Registration isn’t an endorsement. SUGEF has said that being registered doesn’t mean it vouches for a business’s solvency or authorizes it to take deposits or lend as a financial intermediary. It’s one check among several in buying property in Costa Rica, along with a title search and registering your title after the sale.
If you’re still deciding whether to buy at all, our guides to renting versus buying and tips for buying property cover the bigger picture. This guide explains the rules but isn’t legal advice, so confirm your situation with a Costa Rican lawyer or with SUGEF directly.
This guide updates a 2020 column by Joseph Emanuelli, who was a SUGEF-registered broker in Playa Hermosa when he wrote it, on how registration changed Costa Rica’s real estate business. You can reach him through his website, Costarican American Connection.





