SUGEF Registration for Private Lenders in Costa Rica: An Overview

Costa Rica asks people and companies that lend as an organized, habitual activity to register with SUGEF, the General Superintendency of Financial Entities. For anyone who plans to become a private lender here, SUGEF registration for private lenders is part of setting up properly. This overview explains the essentials and points you to the detailed guides published by GAP Investments, the Grupo GAP company that works with lenders.

What registration is

Law 7786, Costa Rica’s anti-money-laundering law, requires providers of certain activities outside the banking system to register with SUGEF. Article 15 bis includes granting credit in an organized, habitual way while using accounts at supervised financial entities. Small activity is excluded: registration is not required when average monthly transactions over the last twelve months are US$5,000 or less, or the equivalent in other currencies.

Registration is not a licence to lend. SUGEF states that it is not an authorization to operate, and registered people and companies are supervised only on anti-money-laundering matters, not on the soundness of their business or loans.

What it involves

The application is filed through SUGEF’s online registration system and signed by the lender, or by a company’s legal representative, as a sworn declaration. Individual lenders prepare:

• identification and activity details;
• criminal record certificates from their countries of birth, nationality and residence;
• a prevention manual, declared under oath;
• a description of the activity and the origin of funds;
• dedicated IBAN accounts at supervised entities;
• registration on the UIF Reportes platform and information in SUGEF’s CICAC.

Companies add a sworn declaration of their shareholding and a certification of their legal representatives. SUGEF’s regulation sets 25 business days to resolve an application, or up to 40 in complex cases.

What continues after registration

Registered lenders appoint a compliance officer or a liaison, depending on how SUGEF classifies them, and keep working ways to detect and report suspicious transactions. The declared accounts are used only for the activity. Registration can be suspended, cancelled or revoked, and a lender who stops lending has ten business days to request deregistration.

How GAP helps with SUGEF registration for private lenders

Many people who lend through GAP are new to lending in Costa Rica, so the registration question tends to come up early. GAP Investments walks lenders through the process and connects them with independent Costa Rican attorneys and compliance professionals who prepare and file the registration. GAP does not file registrations on a lender’s behalf, and the application is the lender’s to sign. Lenders of any nationality can lend through GAP, and Costa Rican residency is not required.

For the full detail, read these GAP Investments guides:

• How to register with SUGEF as a private lender
• Do private lenders in Costa Rica need to register with SUGEF?
• SUGEF registration requirements: a document checklist
• SUGEF compliance for private lenders after registration
• SUGEF registration for foreign lenders
• Inscripción ante la SUGEF (en español)

Frequently Asked Questions

Does SUGEF registration mean a lender’s loans are safe?
No. SUGEF does not supervise the business or loans of registered subjects. A loan’s protection comes from the property, a conservative loan-to-value, first-lien security and the borrower’s ability to repay.

Is there a free checklist?
Yes. GAP Investments offers a free SUGEF Registration Checklist for Private Lenders (PDF), also available in Spanish.

Who do I contact at SUGEF?
SUGEF answers questions about Article 15 and 15 bis registration at articulo15bis-crm@sugef.fi.cr and on (506) 2243-4848.

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. Registration with SUGEF is not an authorization to operate.

Explore lending opportunities with GAP Investments → · WhatsApp us at +506 4001 6413 to get started, call or email info@gap.cr