Bank records under scrutiny: what banks are currently validating for companies in Costa Rica

By Rebeca Sequeira

Financial Analyst.

For Costa Rican companies, updating their bank file still seems like a routine procedure. However, in practice, it's no longer just about confirming an email address, a phone number, or the name of the legal representative. Today, banks are reviewing the company's corporate, financial, and tax information much more carefully to ensure it is complete, up-to-date, and, above all, consistent. This approach reflects the customer due diligence framework overseen by the General Superintendency of Financial Entities (SUGEF) and the use of tools like the Know Your Customer Information Center (CICAC) within the customer knowledge ecosystem.

Furthermore, April makes this issue even more sensitive, because the standard declaration to the Registry of Transparency and Beneficial Owners (RTBF) must be filed between April 1st and 30th each year. In addition, when significant shareholdings change or beneficial owners are modified through other means of control, an extraordinary declaration must be filed within the following 15 business days. In other words, this month forces many companies to simultaneously review their shareholding structure, their actual control, and the information already on file with the bank.

One of the first things banks are reviewing today is who the true owners of the company are and who effectively controls it. Published requirements for legal entities include a legal entity document with shareholdings issued by a notary public, based on a review of the shareholder registry. This registry should detail the shareholders with 10% or more ownership, or the majority shareholder if no one holds that percentage. An electronic document from the Registry of Transparency and Beneficial Owners (RTBF) is also acceptable, provided it is valid, bears the electronic seal of the Central Bank of Costa Rica (BCCR), and clearly identifies the owners or beneficial owners. If this information is incomplete, the bank may again require notarized certification.

In practice, this requirement is resolved much more efficiently when the company keeps its shareholder register up to date, has a simple ownership structure, and verifies that the information in the RTBF (Registry of Companies of Bolivia) matches its corporate documents. The problem is usually not a lack of paperwork, but rather that each document states something different about the same structure. And when that happens, concerns, additional inquiries, and delays begin.

Another area of focus is financial evidence and documentation of the source of income. In public requirements for corporate clients, banks are requesting complete financial statements for the most recent fiscal period, compared to at least one prior period. It is even specified that this set of statements must include a statement of financial position, a statement of changes in equity, a statement of comprehensive income, a statement of cash flows, and notes.

It's important to understand something here: the bank isn't requesting financial statements merely as a formality. What it wants is to verify whether the company's reported operations actually align with its account activity. Therefore, when a company experiences losses, extraordinary transactions, variable income, or contributions from international partners, it's helpful to accompany the statements with a brief executive explanation of the business model and the source of funds. This type of support significantly reduces friction during the review process.

A third point that companies still underestimate is the self-certification of tax residency. Although 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 institution needs to understand in which jurisdiction the company is taxed and whether there are tax ties with other countries. Therefore, answering this section without a minimum review can generate inconsistencies between the bank records, the corporate structure, and the group's actual tax situation.

Changes in legal representation, signatories, and authorized individuals are also gaining significant importance. In procedures published by banks for checking or universal accounts, it is required to complete "Authorization of Signatures" forms, attach a certified copy or power of attorney from the legal representative signing the transaction, and complete the "Party Information Kit" for new legal representatives or signatories, in addition to providing their respective identification. Furthermore, it is clarified that certain representatives may act without any limit on the amount involved and that, if they are not yet registered with the bank, this registration 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. This is not the case. Every time the legal representative, an authorized agent, or an account signatory changes, that change should immediately trigger a bank update. When this isn't done promptly, restrictions, delays, and last-minute procedures arise that could easily have been avoided.

Ultimately, the most important factor isn't the quantity of documents, but their consistency. Today, banks can review shareholding structure, RTBF (Registered Taxpayer Registry), financial statements, legal representation, and the client's overall profile as all parts of the same story. If the bank form says one thing, the financial statements another, and the corporate documentation yet another, the file becomes complicated. Therefore, the best way to address these requirements isn't to react to each one individually, but to organize the corporate information internally before submitting it.

Seen in this light, keeping bank records up-to-date is no longer merely an administrative matter. It's a fundamental corporate practice. And in an environment where April also requires a review of the Registry of Transparency and Beneficial Owners (RTBF), it makes sense to take advantage of this opportunity to align shareholding structure, legal representation, financial information, and banking documentation. This not only reduces issues with the bank but also projects a more organized and better-prepared company.

References used

General Superintendency of Financial Entities (SUGEF), customer due diligence framework and references on the Know Your Customer Information Center (CICAC).

Ministry of Finance, guide on types of declarations of the Register of Transparency and Beneficial Owners (RTBF), including ordinary declaration in April and extraordinary declaration for relevant changes.

DAVIbank (Costa Rica) SA, published requirements for updating files, inclusion and exclusion of signatories, new legal representatives and corporate documentation.