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Regulatory issues (lack of player protection)

In Costa Rica, online gambling has historically developed outside the classical license: companies register as "data processing companies" and target foreign markets. For starting a business, this is cheap and fast, but for the player the model is dangerous: there are no system guarantees and protection mechanisms that are enshrined in law and controlled by relevant authorities in licensing jurisdictions (EU, Panama, renewed Curacao, etc.).


1) Legal vacuum and its consequences

There is no profile regulator for online. Control is of a general administrative and tax nature; there is no specialized body that issues/suspends licenses for online violations.

There are no "rules of the game" for B2C. Mandatory standards for player protection have not been established: verification of the integrity of games, minimum self-defense functions, procedure for handling complaints, requirements for advertising and bonuses.

Extraterritoriality. Operators based in Costa Rica, in theory, should not serve residents of the country. If a local player does play online, he actually finds himself outside of national protection and depends on the jurisdiction of the operator.


2) Where exactly is the player left unprotected

2. 1. Responsible Gambling

There are no mandatory self-exclusion tools, deposit/time limits, timeouts with understandable SLAs.

There is no centralized register of self-excluded and a "single window" for blocking all operators at once.

There are no requirements for staff training and standards for identifying vulnerable players.

2. 2. Honesty and transparency of games

The obligation of independent certification of RNG/games is not enshrined (typically GLI/eCOGRA/iTech Labs in "licenses" of other countries).

There is no single register of approved RTP versions and procedures for checking the return to the player for a dispute.

2. 3. Custody and financial security

There are no rules on mandatory segregation of client funds (separate trust accounts/guarantees).

There is no fund/compensation scheme if the operator goes bankrupt.

2. 4. Resolution of Disputes

There is no mandatory external arbitrator/ombudsman. Complaints are dealt with by the operator himself; further - only a civil law path in a foreign jurisdiction.

There is no transparent SLA/metrics on response timelines and communication standards.

2. 5. Advertising and bonuses

There are no uniform advertising standards (targeting 18 +, banning aggressive "return the loss" messages, restrictions on promises of "risk-free" bets).

There is no unification of bonus rules: vager, maximum bets when wagering, deadlines - everything is determined by the site itself and often in "small print."

2. 6. Data protection and privacy

General privacy standards are not supported by the special requirements of the industry: how game/payment logs are stored, what is the retention of data, who will audit information security - remains at the discretion of the operator.


3) Typical "pain points" for the player

Freezing payments under the pretext of an additional KYC without an understandable deadline.

Retroactive modification of bonus terms, cancellation of winnings due to "violation of the rule," which the player found out about after the fact.

Technical disputes (wager done/not done; rate accepted/canceled) - without independent verification of logs.

Closing access via GEO: the operator suddenly stops serving the country and the "frozen" means require complex correspondence.


4) Comparison with licensing jurisdictions (in general terms)

Malta/Maine/Gibraltar/Spain/Italy: profile licenses, external arbitration, game certification, mandatory RG tools, advertising standards, segregation of funds (or equivalent guarantees).

Panama/Colombia (region): issuance of online licenses by public authorities, regulated dispute procedures and audit of operators.

Curaçao (new LOK regime): Enhanced requirements for compliance, personal permits, responsible gambling and supervision are being phased in - a reputation above the old sub-licence system.

Costa Rica: there is no profile online license → there is no fixed system of protective mechanisms for the player.


5) Risks to local image and economy

Reputational losses. Scandals around payments/bonuses hit the entire ecosystem (hotels, tourism, IT contractors).

Gray legal status online. It is more difficult to attract payment rails and large partnerships, transaction costs are growing.

Churn of responsible players into licensed markets with better protection.


6) What can be improved (reform roadmap)

1. Basic act on online games: define the concepts of operator, game, B2B provider, payment provider.

2. Regulator/administrator: register of permits, suspension procedures, reporting, public sanctions.

3. RG-minimum: self-protection (limits/timeouts/self-exclusion), age verification, personnel training.

4. Integrity and auditing: mandatory RNG/content certification, journaling, independent review of disputes.

5. Finance: segregation of client funds/guarantee deposits/insurance, transparent payment terms.

6. Advertising and bonuses: standards and prohibitions on misleading practices, targeting control 18 +.

7. Ombudsman/ADR: mandatory external complaints mechanism.

8. Information security and privacy: requirements for storage/encryption/retention, audit of providers.


7) Practical advice to players (until the system is reformed)

Check the jurisdiction and license of the site. If the operator is "Costa Rican" by office, it does not mean that it is licensed in Costa Rica; the current external license and its conditions are important.

Read the T&C and bonus rules. Watch the vager, maximum bet when playing, deadlines, excluded games.

Rate the cashier. The withdrawal dates, list of methods, commissions, KYC procedure should be clear.

Look for RG tools. Deposit/time limits, self-exclusion, 24/7 support contacts.

Keep history. Screenshots of the balance, confirmation of bets/wins, correspondence with the support.


8) Recommendations to operators (how to reduce risks and increase trust)

Implement a voluntary standard: RG tools, independent content certification, transparent RTP/logging.

Segregation of funds and payment SLAs (for example, T + 24/48/72 with public metrics).

Public Code of Advertising and Bonus Policy; do not change the conditions retroactively.

Appoint an ADR partner (external arbitrator) and publish the dispute escalation procedure.

Invest in information security and regular external audits.


Costa Rica is convenient as an operating base for business, but for a player, the absence of a specialized online license and regulator means weak or zero state protection. Until the country implements uniform Responsible Gambling standards, game certification, dispute arbitration and financial guarantees, responsibility for safety remains with the player himself and the integrity of the selected operator. The best thing that can be done "here and now" is to carefully check the jurisdiction, the terms of the cash register and the availability of RG instruments, and the business can voluntarily adjust to international standards.

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