A question I hear more often from clients who hold Bitcoin is a simple one: can I still use it to buy property in Costa Rica?
The answer is yes. What has changed is how clearly you need to show where that money came from, and who has to check it along the way.
On June 19, 2026, Costa Rica published Law 10961, and it took effect on September 19. Buying property in Costa Rica with crypto is still legal, but the paper trail is now part of the deal, not an afterthought.
In my crypto real estate guide, I explained how these transactions work. This article is the next step. It covers what the law now requires from the exchanges and escrow providers you use, what your notary has to do before signing, and what changes for the seller.
What Law 10961 Actually Does
Law 10961 is not a crypto law in the way many people expect. It does not create a license, and it does not make Bitcoin legal tender. The law itself says virtual assets are defined without being recognized as legal currency.
What it does is add a new article to Costa Rica's anti-money-laundering law, Law 7786. Companies that exchange, transfer, hold, or administer virtual assets as a business are now obligated parties. That includes exchanges, custodians, crypto payment processors, and OTC desks. They have to register with SUGEF, the financial supervisor, and follow the same kind of controls banks follow.
In practice, that means knowing who their client is, keeping records that let a transaction be reconstructed, checking where transfers come from and where they go, and reporting suspicious activity to the financial intelligence unit.
The part that matters most for real estate is this one. Banks and other obligated parties, including notaries, developers, and real estate brokers, cannot keep a business relationship with a provider that should be registered and is not.
Registration Is Not a Seal of Approval
I want buyers to understand this clearly, because it is easy to misread.
When a provider is registered with SUGEF, it means they are inside the anti-money-laundering system. It does not mean the regulator has approved or endorsed their services. The law says registration is not an authorization to operate.
So registration is a minimum, not a recommendation. You still need to know who you are working with, how long they have been doing this, and how they handle your funds.
The New Checkpoints in a Crypto Purchase
The first is your exchange or custodian. If they operate in Costa Rica, they should be registered with SUGEF. If they are based abroad, they should be regulated for anti-money laundering in their own country.
The second is the escrow. You need to know whether the escrow receives crypto or only dollars, who handles the conversion, and whether that party is registered.
The third, and the most important, is the notary.
What Your Notary Now Has to Do
This is where buyers will feel the change most.
Since July 6, 2026, notaries in Costa Rica follow new guidelines from the Consejo Superior Notarial. When the payment involves virtual assets, enhanced due diligence is mandatory. It is not optional, and it is not up to the notary's comfort level.
The notary has to identify how the price is being paid and record it in the deed. They have to record the equivalent value in dollars or colones at the moment of the transaction. They have to record who sent the funds and who received them, along with the date, the amount, the type of asset, and the wallet addresses or transaction identifiers.
A signed declaration about the origin of your funds is no longer enough on its own. The notary has to ask for proof of how the wealth was built, such as tax returns, a certification from your accountant, records of earlier sales, or documentation of an inheritance.
And if the notary cannot get clarity on who owns the assets, who controls them, or where they came from, they must step back from the transaction and file a report. That applies even if the buyer decides to walk away.
The price in the deed is still written in dollars or colones. Those are the only currencies the National Registry accepts as a reference of value.
What I Am Seeing in the Market Now
What I am seeing in the Costa Rican real estate market is a stronger emphasis on transparency, documentation, and clearly establishing the source of funds before a transaction reaches closing.
For buyers using Bitcoin or other cryptocurrencies, my advice has always been to work with experienced attorneys, reputable escrow companies, and professionals who understand how these transactions are structured. With the new regulatory framework, that preparation becomes even more important.
I do not see this as a negative development for Costa Rica. In fact, I believe greater clarity and accountability can strengthen confidence among international investors. The key is to address these requirements early in the purchasing process rather than letting documentation issues become obstacles during closing.
What to Ask Your Exchange or Escrow Before You Start
My advice is to gather the documents before you fall in love with a property, not after.
Ask your exchange or custodian to confirm their registration status with SUGEF, or their regulatory status in their home country. Ask for account statements in your name that show your purchases, sales, and balances over time. Ask for a record of the conversion that shows the date, time, type of asset, amount, exchange rate, and the dollar equivalent. That is the same information your notary will need to record.
Keep the wallet addresses and transaction hashes for every movement. If you hold your crypto in your own wallet, be ready to show that the wallet is yours.
Then ask your escrow provider how they handle crypto. Do they receive it directly, or only after conversion? Who converts it? Are they registered? A good escrow will be able to answer these questions without hesitation.
Finally, prepare the documents that show where your wealth came from in the first place. Start this early in the process, not in the weeks before closing.
What Changes for the Seller
Sellers need to pay attention too.
If a seller accepts crypto directly, the notary has to record the seller as the beneficiary and record the wallet that received the funds. When the seller later converts those funds, their own bank will see where they came from.
Developers and brokers were already obligated parties under the anti-money-laundering law. Now they also cannot work with providers that should be registered and are not.
There is also an open question I would want any developer to review with their attorney. If a developer accepts crypto and holds or converts it as part of its business, it could start to look like a provider itself. That is a question for legal counsel, not for me, but it is worth asking before agreeing to receive crypto directly.
Some Rules Are Still Being Finalized
The law is in effect, but the detailed operating rules for providers are not final yet. In October 2026, SUGEF held a public consultation on those rules, and some of the proposed details, including the transaction thresholds, could still change.
I mention this because I do not want clients to make decisions based on numbers that may move. What will not change is the direction. More documentation, more traceability, and less room for assumptions.
How I Advise Clients to Approach It
In my experience, the most practical approach for buyers purchasing real estate with Bitcoin or other cryptocurrencies is usually to structure the transaction so the seller ultimately receives US dollars through an established escrow process.
That does not mean cryptocurrency cannot be used directly. There are different ways to structure these transactions depending on the buyer, seller, and professionals involved. However, converting to dollars through a reputable provider often makes the closing process more straightforward and reduces unnecessary complications.
My focus has never been on pushing clients toward one particular payment method. It is about understanding their objectives, how their assets are held, and identifying the most efficient and secure way to complete the purchase.
At Coldwell Banker Vesta Group, we coordinate each transaction with qualified legal, escrow, custody, compliance, and tax professionals. The documentation is not difficult if you have kept good records. It becomes difficult when you try to rebuild years of transactions in the weeks before signing.
Ultimately, my responsibility is to help clients navigate the process efficiently while protecting their interests and ensuring they work with the appropriate professionals.
Questions My Clients Ask About Buying Property With Crypto
Can I still buy property in Costa Rica with Bitcoin?
Yes. Law 10961 does not prohibit buying property with crypto. It brings exchanges, custodians, and similar providers under Costa Rica's anti-money-laundering rules. What changed is the documentation required to show where the funds came from and how they were converted.
Does my exchange need to be registered with SUGEF?
If it operates in Costa Rica as a virtual asset service provider, it should be. Providers based abroad should be regulated for anti-money laundering in their own jurisdiction. Keep in mind that registration is not an endorsement. It only means the provider is inside the anti-money-laundering system.
What will the notary ask for in a crypto purchase?
Expect enhanced due diligence. The notary records the payment method, the dollar or colón equivalent, the sender and receiver, and the wallet addresses or transaction identifiers. They will also ask for proof of how your wealth was built, not just a signed declaration.
Can the notary refuse to complete the purchase?
Yes. If the notary cannot get clarity on who owns or controls the assets, or where they came from, the guidelines require them to step back and file a report, even if the buyer decides not to proceed. Clear documentation is the best way to avoid that.
Should I convert my crypto to dollars before closing?
In my experience, the most practical approach is usually to structure the transaction so the seller receives US dollars through an established escrow process. Crypto can still be used directly, but converting through a reputable provider often makes closing more straightforward. Confirm the right structure with your attorney and tax advisor.
Final Thoughts: Clarity Protects the Buyer
Costa Rica continues to present tremendous opportunities for investors who hold digital assets. I believe the ability to use cryptocurrency to acquire tangible assets, particularly quality real estate in desirable locations, will remain attractive to international buyers seeking both lifestyle benefits and long-term investment value.
This law does not change that. It asks buyers to add one thing: a clear record of where their money came from. A transparent purchase is easier to close, easier to register, and easier to sell one day.
My role is to help clients get that right before it becomes a problem, and to make sure everyone involved in the closing is working the way the law now requires.
Contact Daveed directly for a private conversation
If you are considering buying property in Costa Rica with crypto, I invite you to contact me directly. We can talk about your situation, how your funds are held today, and the cleanest way to bring them to closing.
