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Why a Costa Rican Law Firm Asks for Your Passport and Source of Funds Before Doing Anything

By Quatro Legal Immigration Team | Oct 15, 2026 | Article

Why a Costa Rican Law Firm Asks for Your Passport and Source of Funds Before Doing Anything

It is a legal obligation, not a judgment about you. Under Law 7786, Costa Rica's anti-money-laundering statute, notaries, banks, accountants, trust service providers and anyone who habitually carries out real estate purchases and sales for clients are designated obligated parties registered with SUGEF, the financial superintendency. Collecting and verifying your identity is not something the firm chooses to do. It is something firms are required to do.

Foreign clients frequently read this request as friction or distrust, stall, and lose weeks. Knowing what is coming removes the surprise and sets expactations.

What you will be asked for

RequestedWhy
Passport or official IDCustomer identification and verification is a statutory requirement. Foreigners are identified in Costa Rica with their passport.
Proof of addressPart of the same identification obligation. A utility bill or sworn statement is used as the most common references.
Source of fundsRequired so the firm or the escrow service can document the origin of money entering the transaction. Bank statements, tax forms, investment portfolio information are used as the most common references.
Beneficial ownership, if you are using a companyThe law requires identifying the natural person behind a legal entity, not just the entity.
Additional documentation, in some casesEnhanced measures apply to higher-risk clients and to politically exposed persons or persons with complex estate planning structures.

A firm that does none of this for a property purchase is not being efficient. It is being non-compliant, and its files are the ones that create problems later.

Why beneficial ownership matters more than people expect

If you buy through a Costa Rican company, a common and legitimate structure, the obligation does not stop at the company. The law requires identification of the beneficial owner: the actual human being who ultimately controls it. In other countries this is known as “UBO” Ultimate Beneficial Owner.

This continues after closing. Beneficial ownership must be filed annually under the RTBF regime, with an April 30 deadline. It is an ongoing compliance obligation attached to the company, not a one-time onboarding step, and it is the single most commonly forgotten duty among foreign owners of Costa Rican companies.

What you should get in return

Compliance runs both directions. The information you hand over should buy you a defined engagement. Before sending documents, establish in writing:

  • What exactly the firm is engaged to do, and what falls outside it
  • The fee, the fee basis, and which third-party costs are separate
  • Who your named contact is, and who covers when they are away
  • How often you will receive updates, and in what form
  • How your documents and data will be stored and who can access them
  • What happens to the engagement if the transaction does not proceed

If a firm asks for your passport and source of funds but will not put those six items in writing as part of an engagement letter or services contract, the asymmetry is the problem, not the documentation request.

What the first weeks usually look like

Onboarding and identity verification come first, before substantive work begins. For a property purchase, due diligence follows, with a standard period of roughly 30 days. Nothing irreversible should happen, no funds should move, before the legal review is complete. A preliminary closing statement or quote is advisable.

The sequence matters. Compliance before work, work before money. A firm that proposes moving funds before it has completed either step is departing from normal practice, and that departure is worth questioning.

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Last updated: September 14s, 2026. Written by Gonzalo Rojas Benavides, Founding Partner, Colegio de Abogados de Costa Rica No. 17310. E-mail: grb@quatro.legal

This page describes general procedure in Costa Rica and is not legal advice. Requirements change and vary by case. Confirm current requirements before relying on any timeline or document list here.

Disclaimer: The information provided in this resource is for general informational purposes only and is not intended to constitute legal advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change. For the most accurate and up-to-date information, please contact our office directly. Some images may be AI generated.