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If you’re building a crypto product for the Americas and want a venue that pairs structure with pragmatism, Costa Rica deserves a hard look. The key is to keep v1 narrow, map your real flows (not just your marketing), and evidence the controls you actually run. For the official route, requirements, and a step-by-step service path, see Costa Rica VASP license.
Start with the product, not the label
Regulatory labels don’t move applications forward—clear product narratives do. Write the one-page story a banker or reviewer can read in two minutes: who you serve, the assets and corridors you’ll support in v1, and what happens from onboarding to withdrawal. If your app touches client assets—exchange, OTC, hosted wallets, transfers, on/off-ramps—you’re squarely in VASP territory; that means documented AML/CTF, sanctions, monitoring, and a custody story that stands up in production. If you’re truly non-custodial, your burden is lighter, but embedded routing, matching, or settlement can still pull you into scope. Validate that early, before code hardens.
Controls that actually pass scrutiny
Reviewers and banks are allergic to hand-waving. Your AML/CTF program should reflect the product you’re shipping, not a generic template. Explain how you KYC retail users, how you KYB businesses (and identify UBOs), and how sanctions screening runs at onboarding and on a cadence. Describe monitoring the way an analyst works: rules, escalation thresholds, disposition codes, timestamps. For custody, keep it boring and defensible—HSM or audited multisig for keys, role-based access, withdrawal approvals with dual control, and routine reconciliation that aligns wallets or accounts with your ledger. If you list assets or run an order book, add market-conduct language (disclosures, listing standards, conflict controls) proportionate to your scope.
The evidence bundle that shortens clarifications
Think screenshots and logs over adjectives. Capture an onboarding flow with successful KYC, a sanctions hit and how it’s handled, a transaction alert with analyst notes, a withdrawal approval trail, and a reconciliation extract. For the Travel Rule, don’t say “later”—wire your main corridors and save a handful of message traces (success, non-participant, fallback). Drop it all into a tidy folder with dates. When the same artifacts answer both reviewer and banking questions, your process accelerates and your team stops rewriting prose.
Banking in Costa Rica (what plays in real life)
The predictable path is a two-step: open a fintech-friendly EMI/PSP first so you can invoice, receive funds, and run operations; then add a bank (or a second EMI) for redundancy and currencies once v1 is live. Providers are trying to answer four things: who owns and runs this business (with evidence), what exactly you do (plain English that matches your website and contracts), how funds move (corridors, monthly volumes, counterparties, currencies), and how you keep illicit flows out while safeguarding client assets (segregation, reconciliation, monitoring in action). If those four are crisp and evidenced, onboarding is routine; if they’re fuzzy, you’re in the slow lane.
Architecture choices and their trade-offs
Non-custodial tools keep custody risk low, but beware the “hidden brokerage” trap—auto-routing or matching that amounts to executing for clients. If any part of the path looks like you control settlement, scope expands. This model thrives when your value is analytics, compliance tooling, or UX orchestration that never touches keys.
Custodial wallets invite a deeper look: key governance, dual approvals, hot/cold thresholds, allow-lists for riskier cohorts, and reconciliation discipline. Keep v1 on a small set of well-supported assets, document incident playbooks (compromise, vendor outage, forks), and make evidence easy to produce. The payoff is simpler flows and fewer support edges for mainstream users.
Exchange/OTC should start with spot only: limited listings with clear liquidity, disclosures that explain your spreads/fees, and a clean separation between market-making arrangements and client flows. If you want leverage or derivatives, sequence them after authorization with board minutes and policy updates that reflect reality.
Payments/on-ramp lives and dies on Travel Rule interoperability, sanctions coverage, source-of-funds checks, and a credible counterparty map. If you’re relaying to third-party custodians or exchanges, vendor due diligence isn’t optional—have those assessments on file with renewal dates.
Sequencing in six moves
1) Model mapping. Diagram onboarding → funding → action → withdrawal. Mark who holds keys or can move funds at each step. Confirm geographies and corridors. Identify “nice-to-have” features and defer them.
2) Policy build aligned to flows. Write AML/CTF, sanctions, monitoring, custody, security, and disclosures as reflections of your diagram. If the app can’t yet do allow-lists or dual approvals, either ship them now or state a dated rollout—don’t pretend.
3) Appoint and evidence governance. Name a Compliance Officer with a direct line to top management; approve the policy suite in minutes; prepare fit-and-proper packets for directors/UBOs (IDs, address proofs, short CVs).
4) Evidence pack. Save the screenshots/logs that prove controls, plus Travel Rule traces on your main corridors. Keep files dated and searchable.
5) Submission and clarifications. File a complete pack; respond to questions with short, artifact-backed answers (policy excerpt + screen/log). Don’t expand scope mid-review unless asked.
6) Operations in parallel. Open an EMI/PSP so invoicing and payroll don’t wait on the last clarification. Add a bank (or second EMI) after the base model is stable.
Substance and perception (your underrated edge)
You don’t need a big headcount, but you do need consistency. Legal names and addresses should match across contracts, invoices, your website, and onboarding forms. Keep a resolutions log for anything material—banking access, officer appointments, listing policy changes. Show a lightweight operational footprint: the tools you use, how access is controlled, where records live, how incidents are triaged. This reads as maturity, not bureaucracy, and it’s what counterparties remember when they recommend you internally.
Costs without surprises
Budget in buckets rather than chasing a single “license fee.” There’s one-off setup (advisory/policy drafting, application prep), technology and security (KYC/KYB, Travel Rule, custody tooling, monitoring stack, pen-testing), and ongoing compliance (officer time, audits, reporting, training, renewals). Under-resource any of these and you’ll pay in delays or provider refusals—both costlier than a small buffer up front.
Common traps and simple fixes
Vague activity descriptions (“crypto platform”) that contradict your UI slow everything down; write a plain-English narrative first and mirror it everywhere. Missing UBO evidence or blurry KYC scans create week-long loops; triple-check documents before you file. Policy–product mismatches (“we run allow-lists” when you don’t) invite detailed follow-ups; claim only what exists. Finally, Travel Rule promises without traces are an automatic speed bump; wire two corridors and save proofs before you submit.
FAQ (the short version)
Do all crypto apps need authorization? If you can move or safeguard client assets, yes—expect VASP scope. Purely non-custodial tools may be lighter, but validate before you build.
How long does it take? Completeness beats optimism. Teams that file a coherent story with artifacts and a narrow v1 tend to move faster than teams with broad promises and no proofs.
What convinces banks? A clean ownership picture, a consistent activity narrative, a simple flow diagram with volumes/corridors, and evidence of segregation, reconciliations, sanctions/KYC, and monitoring in action.
Can we launch with EMI/PSP only? Many do. It keeps revenue moving, then a bank or second EMI adds redundancy and currencies once controls are stable.
If you’d rather have an experienced team run the filings and assemble the bank-ready evidence while you focus on product, LegalBison typically leads the heavy lifting and aligns controls with what you’re actually building—details at legalbison.com.
