How to Register With SUGEF as a Private Lender in Costa Rica

If you plan to lend money in Costa Rica as an ongoing activity, and not just once for a relative, you will want to register with SUGEF. Registration brings private lenders inside Costa Rica’s anti-money-laundering framework, and SUGEF’s rules restrict supervised financial entities from serving people who should be registered and are not. This guide explains who registration applies to, what SUGEF asks for, and how the process runs from start to finish.

One point first, because it is misunderstood more than any other. Registration with SUGEF is not a licence to lend, and it is not an endorsement. SUGEF states publicly that registration is not an authorization to operate, and that it supervises registered people and companies only on anti-money-laundering matters, not on the soundness of their business or their loans.

Who needs to register with SUGEF

Costa Rica’s anti-money-laundering law, Law 7786, lists activities outside the banking system whose providers must register with SUGEF. Article 15 bis includes people and companies that grant credit in an organized, habitual way while using accounts at supervised financial entities.

SUGEF’s rules exclude small activity: registration is not required when the average of your monthly transactions over the last twelve months is US$5,000 or less, or the equivalent in other currencies. Property-backed loans usually involve much larger amounts, so a lender who plans to fund loans regularly should expect registration to apply. A Costa Rican attorney can confirm it for your exact situation. We look at the question in more depth in do private lenders in Costa Rica need to register with SUGEF?

What to prepare before you apply

Most of the work happens before the application is filed. For an individual lender, SUGEF’s registration regulation asks for:

• Identification and activity details: full name, ID number, nationality, country of birth, any trade name, your activities and your address.
• Criminal record certificates from your country of birth, your country of nationality and your country of residence.
• A sworn declaration that you have a prevention manual covering money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction.
• A description of your activity and the origin of your funds.
• IBAN account numbers at SUGEF-supervised entities, used exclusively for the registered activity.
• Registration on UIF Reportes, the platform of the Financial Intelligence Unit of the Costa Rican Drug Institute (ICD).
• Completed information in the CICAC, SUGEF’s know-your-customer information centre.

Companies provide the same core information plus a sworn declaration of their shareholding, supported by a notarial certification or the beneficial-ownership register, and a certification of their legal representatives from the National Registry or a notary. Every item is explained in our SUGEF registration requirements checklist, and you can get the free SUGEF Registration Checklist for Private Lenders (PDF) to work through it.

How to register with SUGEF, step by step

1. Confirm that registration applies to you. Your activity, structure and volume decide it. This is a conversation for a Costa Rican attorney or compliance professional.
2. Open or confirm your accounts. The IBAN accounts you declare must be at supervised entities and dedicated to the activity. Banks set their own requirements for new accounts, so start this step early.
3. Put your prevention manual in place. You will declare under oath that it exists, so it should be real and fit the way you lend.
4. Complete UIF Reportes and the CICAC, and gather your certificates and certifications.
5. File the application through SUGEF’s online registration system for obligated persons. It is signed by you or, for a company, the legal representative, and it carries the weight of a sworn declaration.
6. Answer any correction request. If something is missing, SUGEF can ask for corrections once and give you at least ten business days to respond.
7. Wait for the resolution. The regulation gives SUGEF 25 business days to resolve, or up to 40 when the case is complex.

What happens once you are registered

Registration has no expiry date, but it is not unconditional. SUGEF can suspend, cancel or revoke a registration, and a suspension comes with a period to fix the problem. Registered lenders also carry ongoing duties: depending on how SUGEF classifies you, you appoint either a compliance officer or a liaison and tell SUGEF within three business days, and you need working ways to detect and report suspicious transactions. If you stop lending, you have ten business days to request removal from the register. Our guide to SUGEF compliance for private lenders covers these duties.

Where GAP fits

We do not file registrations for lenders, and the application is yours to sign. What we do is walk you through the process: what it involves, what to gather, and how it fits with lending on property-backed loans through GAP. We then connect you with independent Costa Rican attorneys and compliance professionals who prepare and file the registration with you.

Registration and lending run side by side. Loans through GAP start at US$50,000, lenders hold a first-lien position, and the borrower pays the lender directly. Any nationality can lend, and Costa Rican residency is not required. See how lending works for the full picture.

Frequently Asked Questions

Is SUGEF registration a licence to lend?

No. SUGEF says registration is not an authorization to operate. It places you under anti-money-laundering supervision only and says nothing about the quality of any loan.

How long does SUGEF take to decide?

The regulation sets 25 business days for SUGEF’s resolution, or up to 40 for complex cases. Time spent answering a correction request comes on top, so a complete application is the fastest route.

Can I register if I do not live in Costa Rica?

The requirements anticipate foreign applicants: they ask for criminal records from your countries of birth, nationality and residence. Your attorney will confirm how to prepare documents issued abroad. Our guide to SUGEF registration for foreign lenders goes further.

Where can I ask SUGEF directly?

SUGEF answers questions about Article 15 and 15 bis registration at articulo15bis-crm@sugef.fi.cr, and its public line is (506) 2243-4848.

Talk to us before you fund your first loan

Tell us where you are in the process. We will explain what registration involves for you, introduce you to independent professionals who can file it, and show you current lending opportunities. Contact GAP Investments to start. Nothing proceeds without your decision, and no outcome is promised.

This article is for general information only and is not investment, legal, or tax advice. SUGEF requirements can change; confirm the current rules with SUGEF and a qualified Costa Rican attorney before filing. Registration with SUGEF is not an authorization to operate and does not guarantee any loan or return.

WhatsApp us at +506 4001 6413 to get started, call 855-562-6427 from the US or Canada, or email info@gap.cr.

Article by Glenn Tellier (Founder of CRIE and Grupo Gap)