Apr 29, 2026
By: Rebeca Sequeira
One of the first points that banks are currently reviewing is who the real owners of the company are and who effectively controls it. In requirements published for legal entities, a corporate certificate with shareholding participation issued by a notary based on the shareholder register is requested, detailing the shareholders with 10% or more participation, or the majority shareholder if no one reaches that percentage. The electronic document from the Registry of Transparency and Final Beneficiaries (RTBF) is also accepted, provided it is current, has the electronic seal of the Central Bank of Costa Rica (BCCR) and allows the owners or final beneficiaries to be clearly identified. If this information is not complete, the bank may again require a notarial certification.
In practice, this requirement is resolved in a much more orderly manner when the company keeps its shareholder register up to date, has a simple ownership chart and reviews that what appears in the RTBF matches its corporate documents. The problem is usually not the lack of papers, but rather that each document says something different about the same structure. And when that happens, observations, additional questions and delays begin.
Another front is financial evidence and support for the source of income. In public requirements for corporate clients, banks are requesting complete financial statements for the last fiscal period, comparative with at least one prior period. It is even specified that this set must include the statement of financial position, statement of changes in equity, statement of comprehensive income, statement of cash flows and notes.
Here it is worth understanding something: the bank is not asking for financial statements merely as a formality. What it wants is to validate whether the operation that the company claims to have truly matches the movements in its accounts. Therefore, when a company has losses, extraordinary movements, variable income or international shareholder contributions, it helps to accompany the statements with a short executive explanation of the business model and the source of funds. This type of support significantly reduces friction in the review.
A third point that companies still underestimate is the tax residence self-certification. Although it is sometimes seen as a simple form, it is actually linked to the due diligence obligations associated with the Common Reporting Standard (CRS). In practice, this means that the financial entity needs to understand in which jurisdiction the company pays taxes and whether there are tax links with other countries. Therefore, completing this section without a minimum review can create inconsistencies among the banking file, the corporate structure and the tax reality of the group.
Changes in legal representation, signatories and authorized persons are also becoming very important. In processes published by banks for checking or universal accounts, it is required to complete “Signature Authorization” forms, attach a literal certification or power of attorney of the legal representative who signs the request, and complete the “Associated Parties Kit” for new legal representatives or new signatories, together with their respective identification. It is even clarified that certain representatives must act without a monetary limit and that, if they are not yet registered with the bank, that process must be completed first.
This is one of the most common operational errors in companies. Many believe that, because the change has already been registered with the National Registry, the bank will automatically reflect it in its systems. That is not the case. Every time the legal representative, an attorney-in-fact or an account signatory changes, that change should immediately trigger a banking update. When this is not done on time, restrictions, delays and last-minute procedures appear that could perfectly have been avoided.
In the end, the most important point is not the number of documents, but the consistency among all of them. Today the bank can review the shareholding structure, the RTBF, the financial statements, the legal representation and the general customer profile as parts of the same story. If one thing is stated in the bank form, another in the financial statements and another in the corporate documentation, the file becomes complicated. Therefore, the best way to resolve these requirements is not to react to them one by one, but to internally organize the corporate information before submitting it.
Seen this way, keeping the banking file up to date is no longer a merely administrative matter. It is a basic practice of corporate order. And in an environment where April also requires a review of the Registry of Transparency and Final Beneficiaries (RTBF), the reasonable approach is to use that moment to align shareholding structure, legal representation, financial information and banking documentation. This not only reduces issues with the bank; it also projects a more organized and better prepared company.
References
General Superintendence of Financial Entities (SUGEF), customer due diligence framework and references to the Know Your Customer Information Center (CICAC).
Ministry of Finance, guide on types of filings of the Registry of Transparency and Final Beneficiaries (RTBF), including the ordinary filing in April and the extraordinary filing for relevant changes.
DAVIbank (Costa Rica) S.A., published requirements for file updates, inclusion and exclusion of signatories, new legal representatives and corporate documentation.