BLP institutes a new practice area: Anti-money Laundering Compliance

BLP announces the formation of an important new practice area, Anti-money Laundering Compliance, staffed by a group of professionals with extensive experience in the implementation of regulatory and voluntary compliance programs. The introduction of the new practice area was necessitated by the international community’s ongoing development of strategies for the prevention of money laundering and the financing of terrorism.

For years, Costa Rica has pursued an active policing trend, approving regulations that initially involved financial entities, then the subjects that manage third-party funds, and most recently, commercial enterprises and non-designated professionals. Current legislation, which incorporates the risk-based approach (RBA) to crime detection, imposes the obligation to establish criteria and policies, due diligence, and reporting procedures not only on financial institutions, but also on lenders, credit and debit card operators, wire transfer remitters, jewelers, real estate developers and brokers, lawyers and notaries, and any other entity that exchanges money in the course of doing business.

Keeping pace with RBA developments, the Firm’s Anti-money Laundering Compliance practice provides legal services in the following areas:

  • Registration with the General Superintendence of Financial Entities (single purpose companies)
  • Structuring an RBA framework encompassing policies, programs, rules and procedures of the entity, including compliance manuals and “know your client” evaluations, as well as monitoring an entity’s adherence to the rules, along with a periodic review of compliance
  • Due diligence processes
  • Appraisal of the legal risks to the entity’s management
  • Advice on the structuring and functioning of the responsible support bodies, such as the Board of Directors, Compliance Committee, Internal Auditor, Technological Service provider, and Risk Manager
  • Instruction in the preparation of an annual agenda for the entity’s compliance administration
  • Overview of the client’s compliance management capability
  • Training on how to comply with regulations on the prevention of money laundering, funding of terrorism, and ­financing of the proliferation of weapons


For additional information, please contact Andrés López, Partner in charge of the practice.