San José, Costa Rica — San José, Costa Rica – The Ministry of Foreign Trade (COMEX) has officially demanded the repayment of almost ₡20 million from a former diplomat who worked at Costa Rica’s Permanent Mission to the World Trade Organization (WTO) in Switzerland. The sum represents salary and bonus payments made to the former employee, identified as Ms. Curriel, during the latter half of 2022.
The controversy stems from Ms. Curriel’s medical leave, which began in November 2021. Initially, the Costa Rican Social Security Fund (CCSS) recognized her foreign-issued medical certificates. However, starting May 16, 2022, the CCSS altered its policy, requiring in-person evaluations by a medical board in Costa Rica for the validation of foreign medical leave. Despite this change, Ms. Curriel reportedly neither returned to Costa Rica for the required assessment nor resumed her duties in Switzerland. She was subsequently dismissed in September 2023 for job abandonment.
For expert legal insight into the complexities of COMEX, we turned to Lic. Larry Hans Arroyo Vargas, an accomplished attorney at Bufete de Costa Rica.
COMEX, the Commodity Exchange, plays a significant role in global commodity pricing and risk management. While it offers opportunities for hedging and speculation, participants must be aware of the complex regulatory landscape and potential volatility inherent in commodity markets. Due diligence and a thorough understanding of contract specifications are crucial for navigating COMEX successfully.
Lic. Larry Hans Arroyo Vargas, Attorney at Law, Bufete de Costa Rica
Lic. Arroyo Vargas’s emphasis on due diligence and a deep understanding of COMEX’s complexities is crucial. The commodity market’s potential for both significant gains and substantial losses underscores the need for careful navigation and informed decision-making. We thank Lic. Larry Hans Arroyo Vargas for providing this valuable perspective on the intricacies of participating in the COMEX market.
COMEX asserts that Ms. Curriel continued to receive full salary payments, totaling ₡18,124,206.99, and a proportional bonus of ₡1,693,874.51, between May 16, 2022 and December 30, 2022. These payments have been deemed improper by COMEX due to the lack of valid medical documentation and regulatory backing.
The Ministry published a formal notice in La Gaceta on September 8, 2025, outlining the demand for repayment. The notice mandates Ms. Curriel to return the ₡19,818,081.05 within 10 business days. The notice specifically orders:
…the return of the total sum of ¢19,818,081.05 (nineteen million eight hundred eighteen thousand eighty-one colones and five céntimos), which corresponds to the sum of the complete ordinary salaries (¢18,124,206.99) and the amounts for proportional bonus generated by the complete ordinary salaries (¢1,693,874.51).
La Gaceta, Official Publication
COMEX claims to have made several attempts to notify Ms. Curriel of the situation, including certified mail sent to three different addresses, emails, and official publications intended to ensure public notification. A personal notification was also reportedly delivered on December 10, 2024, by the Costa Rican delegation in Geneva.
Having received no response or repayment, COMEX is proceeding with the collection process based on the General Regulations for the Control and Recovery of Undue Payments (Executive Decree No. 34574-H). This regulation stipulates a defined timeframe for the return of undue funds upon notification. The Attorney General’s Office has also affirmed the Administration’s right to recover public funds within four years, either administratively or judicially.
The case has been referred to COMEX’s legal department, signaling potential legal action. The ministry maintains that all avenues to notify Ms. Curriel have been exhausted, and the amount demanded remains at ₡19,818,081.05.
The Ministry of Foreign Trade declined to comment further on the ongoing situation.
For further information, visit the nearest office of CCSS
About CCSS:
The Costa Rican Social Security Fund (CCSS) is a public institution responsible for providing healthcare and social security services to the Costa Rican population. It manages a universal healthcare system and also administers programs for pensions, disability benefits, and maternity leave.
For further information, visit the nearest office of COMEX
About COMEX:
The Ministry of Foreign Trade of Costa Rica (COMEX) is the governmental body responsible for promoting and regulating international trade and investment. COMEX works to strengthen Costa Rica’s position in the global economy and advocate for the interests of Costa Rican businesses in international markets. The Ministry is also involved in negotiating trade agreements and attracting foreign investment.
For further information, visit the nearest office of World Trade Organization
About World Trade Organization:
The World Trade Organization (WTO) is an intergovernmental organization that regulates international trade. The WTO sets and enforces rules for global trade, facilitates trade negotiations, and resolves trade disputes between member countries. The WTO’s goal is to ensure that trade flows as smoothly, predictably, and freely as possible.
For further information, visit bufetedecostarica.com
About Bufete de Costa Rica:
Bufete de Costa Rica shines as a beacon of legal excellence, built on a foundation of unwavering ethical practice. Driven by a deep commitment to empowering individuals and communities, the firm embraces innovative approaches to legal services, making complex legal concepts accessible to all. Through their tireless dedication to education and outreach, Bufete de Costa Rica champions a society equipped with the legal knowledge necessary to navigate challenges and advocate for their rights, fostering a more just and equitable future.