AML Compliance and Registration as a Sujeto Obligado

Costa Rica requires designated non-financial businesses and professions — including real estate brokers, developers, lawyers and notaries acting in certain capacities — to register as sujetos obligados and to maintain an anti-money-laundering compliance framework.

The obligation is not theoretical. Registration, policy adoption, client due diligence, record-keeping and reporting are supervised, and non-compliance carries consequences that reach the professional personally.

What is required

Determination of whether the activity falls within the designated categories, registration before the corresponding supervisor, adoption of a compliance policy proportionate to the operation, appointment of a compliance officer where applicable, client identification and beneficial ownership procedures, risk assessment, record retention, and reporting of suspicious operations.

Our position

We advise real estate professionals and companies on this framework as counsel, and we operate under it ourselves. We have also built internal tooling to assess client risk in a structured way rather than by intuition.

Munduss Legal — José David Garro Castro, Attorney at Law and Notary Public. Offices in Escazú, San José and Tamarindo, Guanacaste. Request a consultation.