Setting Up a Crypto Company or VASP: Panama vs Costa Rica

This is a reading of public rules as of 9 October 2026, not a legal opinion and not a filing. A local lawyer has to confirm the gazette, the SUGEF register, and the bank’s own policy before anyone incorporates or takes client money. If a figure is not in a source listed at the end, it is not stated here.

As of October 2026, reports indicate Panama does not have a VASP licence you can apply for. Check the Gaceta Oficial. Costa Rica’s new rule is a SUGEF registration for anti-money-laundering supervision, and the statute says that registration is not an authorization to operate. Check current status with SUGEF before you treat that register as open. A company in either country can still be formed under ordinary corporate law. Formation is not the same thing as permission to exchange, custody, or transfer virtual assets for customers. This is not legal advice.

Use this page for the company and the registration question. The Costa Rica vs Panama hub keeps the expat comparison: safety, residency, cost, and the broad tax table. Crypto tax owns source rules, CRS, and CARF. Is Panama safer than Costa Rica? owns homicide counts and cities. Business establishment is how this firm incorporates. Commercial analysis is whether the model belongs in either market.

What “VASP” means here

VASP is the FATF name for a virtual-asset service provider: a business that, for or on behalf of another person, exchanges virtual assets and fiat, exchanges one virtual asset for another, transfers them, safekeeps or administers them, or participates in issuing or selling them. Panama’s draft uses the Spanish PSAV for the same idea. A holding company that only owns tokens for its own treasury is not automatically that business. The line is fact-specific, and this page does not draw it for you.

Panama: a company, not a VASP licence

As of October 2026, reports indicate Panama has no dedicated VASP statute in force. The National Assembly has described Project of Law 326 as a bill on supervision, registration, and control of virtual-asset service providers, and as still in a subcommittee of the Economy Committee. A bill is not a law. Check the current status of that project with the National Assembly, and check the Gaceta Oficial for any law promulgated since. An earlier crypto project is widely reported not to have survived; we are not citing a case number until counsel confirms it. This is not legal advice.

The Chambers 2026 Panama guide says the Superintendency of Banks has stated that the exchange, investment, purchase, sale, or commercialization of cryptocurrencies is not specifically regulated and sits outside the Superintendency’s direct supervision, while banks are still expected to apply due diligence. We have not reproduced an SBP circular here. Treat that sentence as a secondary summary until the circular is on the file.

What you can do, subject to ordinary corporate, tax, and AML rules, is form a Panamanian company. That is establishment work: articles, a resident agent, a public-registry filing, and a legal representative. As of October 2026, reports indicate that filing does not put the company on a VASP register. Check the Gaceta Oficial before you describe one as open. If the activity makes the firm an obligated subject under the existing anti-money-laundering law, the obligations can apply even without a VASP statute. Do not assume silence means “no AML.”

Tokens that look like securities can still be a Superintendency of the Securities Market question. Custody and fiat on-ramps can still touch banking and the financial-intelligence unit. Scope is activity by activity.

Costa Rica: registration, and the statute says it is not a licence

Law 10961 was published on 19 June 2026 in Alcance No. 78 to La Gaceta No. 113. It adds article 15 quater to Law 7786, the anti-money-laundering statute. The Costa Rican Drug Institute’s note of the same day describes the reform as the VASP framework for FATF-style prevention of money laundering, terrorist financing, and proliferation financing.

The article, as published, requires providers of virtual-asset services to register with SUGEF, the general superintendency of financial entities. SUGEF supervises them for that prevention regime on a risk basis and keeps a single register. The same article says the inscription does not represent an authorization to operate. Providers must keep the registration information current. Duties described in the law and in the Institute’s note include customer due diligence, identification of beneficial owners, monitoring, record-keeping, suspicious-transaction reports, and risk-based controls. A later CONASSIF regulation is supposed to fit those duties to the sector.

The closing line of Law 10961 says it takes effect three months after the 19 June 2026 publication. As of October 2026, reports indicate a CONASSIF regulation may still be required before SUGEF opens a public registration window. Check current status with SUGEF before you treat registration as open. Until SUGEF shows an open procedure, “registered VASP” is not a status you should print on a website. This is not legal advice.

Older SUGEF circulars about articles 15 and 15 bis of Law 7786 are a different list of obligated subjects. Do not treat circular SGF-2421-2025 as the VASP rule. It predates article 15 quater and speaks to those earlier articles.

Side by side

Question	Panama	Costa Rica
Dedicated VASP regime in force?	As of October 2026, reports indicate no law in force. Project of Law 326 was described as still a bill. Check the Gaceta Oficial.	Law 10961 adds article 15 quater. The statute says it takes effect three months after the 19 June 2026 publication. Check SUGEF for whether the procedure is open.
What the state gives you	No VASP licence to apply for. An ordinary company is a different act.	SUGEF inscription for AML supervision. The statute says it is not an operating authorization.
Implementing rule	None located for a VASP register. Check the Gaceta Oficial.	As of October 2026, reports indicate the CONASSIF regulation may not have opened the window. Check current status with SUGEF.
Bank account	Not included. Dollar banking is the practical draw, decided bank by bank.	Not included. A bank may ask about the SUGEF file once the register is real.
Free zone or special regime	A zone licence is not a VASP registration. See the free-zone guide and Panama Pacifico.	A Costa Rican company is still a Costa Rican company. The zone question does not erase article 15 quater.

Which banking is easier?

Neither country owes a crypto business an account. Panama’s advantage, in practice, is that the economy already runs on the US dollar alongside the balboa, and the banking center is used to international companies. That is not a published list of banks that onboard exchanges. Chambers’ summary of the banking supervisor is the cautious version: crypto dealing is outside direct bank-supervisor licensing, and banks still have to know their customer. Expect a compliance file: owners, source of funds, what the product does, and where the money settles. A generic “crypto-friendly” formation package does not open the account.

Costa Rica is also bank by bank. Once article 15 quater is operational, a bank’s question is likely to be whether the firm is inside the SUGEF perimeter and whether the registration file exists. We are not stating that banks are legally barred from unregistered providers. That point needs a reading of the regulation, which was not confirmed as published for this note.

Speed follows the same split. Incorporating a company can be the quick part in both places. The slow part is the compliance story a correspondent bank will accept. Costa Rica’s registration cannot be faster than the procedure SUGEF actually opens. Check that status with SUGEF. As of October 2026, reports indicate Panama has no VASP licence to apply for, so that step cannot be faster than a law that is not yet in the Gaceta Oficial.

What this page will not do

It will not quote a government fee, a processing time, or a minimum capital for a VASP licence. Those numbers are not in a statute we could apply. It will not call a digital-nomad visa, a rentista visa, or any other residence permit a substitute for registration. Residence sits on the hub. Tax sits on the crypto tax page, including CRS and the OECD crypto reporting framework. Safety sits on the crime comparison.

If you want the company structured against that record, establishment and strategy and market validation are the service pages. The consultation form on this page uses the same HubSpot consultation form as the rest of the site.

Sources

• National Assembly of Panama, subcommittee note on Project of Law 326 (supervision, registration, and control of virtual-asset service providers): asamblea.gob.pa.
• Law 10961, published 19 June 2026, Alcance No. 78 to La Gaceta No. 113, adding article 15 quater to Law 7786: imprentanacional.go.cr.
• Instituto Costarricense sobre Drogas, note of 19 June 2026 on the virtual-asset reform: icd.go.cr.
• Chambers, Blockchain & Crypto-Assets 2026, Panama (secondary summary of the banking supervisor’s position and of the absence of a VASP regime): practiceguides.chambers.com.