Cuba's economy, mapped: who controls what, and the lawful way to back its entrepreneurs.
The New Cuba Opportunity Atlas maps every major asset in Cuba: who controls it, who it was confiscated from, and what a rebuild would take. It also documents the one lane U.S. law allows today, payments to Cuba's independent private sector. Not legal advice; not authorization for any transaction.
QvaPay, a U.S. fintech, is the payment rail we document. Our atlas of an open and prosperous Cuba.
What September 30 broke — and how QvaPay keeps the lawful lanes open
The rule closed the offshore routes and the bank accounts of Cuban entrepreneurs. It left open the payments U.S. law authorizes — and those are the ones QvaPay is built to run: screened end to end, with no Cuban state party and no third-country bank.
U.S. banks may no longer hold accounts for Cuban entrepreneurs, and existing ones must be blocked (§515.584(h)(2) withdrawn; OFAC FAQ 1273).
QvaPay is a payment service, not a bank. It processes the payments U.S. law authorizes — remittances in, contractor and export payments — as transactions ordinarily incident to them (§515.421; OFAC FAQ 756).
Every fund flow →The U-turn is gone: a dollar wire that starts and ends outside the U.S. with a Cuban interest is rejected. The Panama and Hong Kong import route — and its 12% toll — is dead (§515.584(d); FAQ 1272).
The Cuban buyer pays a U.S. seller from its QvaPay business account: QvaPay wires dollars from its U.S. bank to the seller's U.S. account against the FOB/FCA Port Everglades invoice in the buyer's name, the export authorization and the EEI. No third-country bank, no cash processor in Havana.
The Florida route →A Cuban business may no longer pay a supplier outside the United States for foreign goods or services through U.S. rails.
QvaPay points Cuban buyers to U.S. sellers that own the goods in the U.S. before the order — U.S. manufacturers, U.S. distributors, or QvaPort (launching in November), which buys its stock in advance with its own money, U.S.-made or held in the Florida foreign-trade zone.
Why, and what works instead →Indirect dealings with Cuba Restricted List entities are now prohibited, and structuring around them is itself a violation (§515.209; §515.201(c)). One GAESA-linked processor or importer anywhere in the chain taints the payment.
Sentinel screens every party and every leg — sender, recipient, owners, exporter, carrier — against the SDN List, EO 14404 designations and the Restricted List. No state bank, FINCIMEX or state importer is ever payer or payee.
QvaPay Sentinel →The only flow pending with OFAC is import financing (Case CU-2025-1426925-1), and it is not offered. QvaPay, Inc. is a FinCEN-registered money services business, not a bank. Not legal advice.
Pay Cuba's independent entrepreneurs through QvaPay
U.S. sanctions authorize remittances and certain payments to Cuba's independent private sector (31 CFR §515.570(g)(3)): self-employed cuentapropistas, freelance developers, small farmers and small private businesses (MIPYMEs). Every payment is screened with QvaPay Sentinel and settled peer-to-peer (cash moves between peers; QvaPay never touches it), never through Cuban state banks or regime processors.
We do not name businesses to pay, and we do not decide that any transfer is authorized. That is a question for OFAC counsel. How the support lane works →
The rebuild, mapped in advance
Ports, energy, water, rail, mining and industry: the full map of Cuba's state economy and the firms that could rebuild it. Information only. No U.S. money flows. Register interest for a post-sanctions Cuba or for non-U.S. capital.
Give to the Catholic charities feeding Cuban families
Caritas Cuba, Friends of Caritas Cubana, Catholic Relief Services and more reach families through parishes, not the state. Give by card, Apple/Google Pay, U.S. bank, PayPal, crypto or QvaPay balance, and get a receipt.
Donate now →