⚠ COMPLIANCENot investment advice. U.S. sanctions restrict Cuba investment to the licensed independent private sector. Every transaction is KYC'd, OFAC-SDN & Cuba Restricted List screened, confirmed as an independent private entity (≤100 employees), and subject to OFAC counsel. No money flows to state, JV, GAESA, Restricted-List or confiscated-property counterparties.

The legal posture — a feature, not fine print

Compliance

A U.S. person cannot wire money into Cuban state infrastructure — ports, energy, water, rail, refineries, large hotels, state industry — and does not take equity in Cuban MIPYMEs. What is legal is supporting the licensed independent private sector through OFAC-authorized remittances and payments (31 CFR §515.570, §515.578, §515.542) routed via QvaPay. This site is built so the line is enforced in code: a Support button can only appear on the 6 private-sector entries that clear every screen.

Enforced in code

A single compliance engine decides every CTA: canSupport() returns true only when an asset is private + an 'opportunity' entry tagged support_via_qvapay AND its controlling counterparty clears the Cuba Restricted List (236 entities), the OFAC SDN list, and the Prohibited Accommodations List (429 hotels). The build fails if any record sets investable_us=true (there is no equity lane) or contradicts this.

Legal authorities

31 CFR 515.201(c)

Anti-evasion — any transaction that evades or avoids, has the purpose of evading or avoiding, causes a violation of, or attempts to violate the embargo prohibitions is independently prohibited. Structuring around the embargo is itself a violation.

31 CFR 515.209

Cuba Restricted List prohibition — bars most direct financial transactions with entities/subentities on the State Department's Cuba Restricted List (CRL), which are determined to be controlled by or to benefit the Cuban military, intelligence, or security services (e.g., GAESA and its affiliates).

EO 14404 (2026-05-07)

Issued May 1, 2026 (designations beginning May 7, 2026). IEEPA-based order expanding Cuba sanctions: authorizes sector-based designations of the Cuban economy and secondary sanctions on foreign financial institutions for significant transactions with blocked persons. First designation: GAESA. OFAC adopted a limited non-targeting posture for foreign-person wind-down of GAESA dealings through June 5, 2026.

31 CFR 515.340

Defines 'independent private sector entrepreneur' (effective May 29, 2024, replacing 'self-employed individual'): a Cuban national who is NOT a prohibited Government of Cuba official (515.337) or prohibited Communist Party member (515.338), and who is an owner (including a cuentapropista) or employee of a small private business/cooperative/sole proprietorship of up to 100 employees; an independent contractor/consultant; a small farmer who owns land; a small usufruct farmer; or a private cooperative/small business of up to 100 employees owned only by such individuals. This is the gating definition for the private-sector general licenses.

31 CFR 515.582

Authorizes persons subject to U.S. jurisdiction to engage in all transactions, including payments, necessary to import certain goods and services produced by independent Cuban entrepreneurs, as set out on the State Department's Section 515.582 List. Requires documentary evidence of the entrepreneur's independent (non-state-owned/controlled) status.

31 CFR 515.542

Authorizes all transactions, including payments, incident to mail and telecommunications services involving Cuba — data, telephone, internet connectivity, radio/TV, news wire feeds, roaming agreements, satellite transmissions — and contracts with telecom providers serving particular individuals in Cuba (excluding prohibited officials/Party members).

31 CFR 515.578

Authorizes export/reexport from the U.S. to Cuba of services incident to internet communications (messaging, email, social networking, web hosting, domain registration, video conferencing, e-learning, etc.) and supporting services (software design, IT management, cloud-based services), and authorizes importation of Cuban-origin software.

Helms-Burton

Title III — treble-damages lawsuits for "trafficking" in confiscated property, broadened by the Supreme Court's Havana Docks ruling (May 21, 2026). Title IV — personal U.S. visa bars for officers and principals of trafficking entities. Both are reasons U.S. capital must stay out of confiscated infrastructure.

Key dates

2020-12-21GAESA originally placed on the SDN List and Cuba Restricted List
2024-05-29CACR amendments effective — 515.340 redefines 'independent private sector entrepreneur'; expanded private-sector general licenses
2026-03-18Cuba rule change allowing diaspora/foreign equity in MIPYMEs (private SMEs); formalized via Official Gazette package published May 5, 2026
2026-05-01EO 14404 signed — expanded IEEPA-based Cuba sanctions and secondary-sanctions authority
2026-05-07First EO 14404 designations: GAESA, Moa Nickel S.A., Ania Guillermina Lastres Morera
2026-05-18Second tranche: MININT, PNR, DGI and eleven senior officials (incl. Rodriguez Lopez-Calleja, Rosabel Gamon Verde)
2026-05-21SCOTUS Havana Docks ruling (8-1, Thomas, J.) broadened Title III Helms-Burton trafficking liability for use of confiscated Cuban property
2026-06-04Third tranche: MINFAR, Minera La Victoria, CDR, ICAP/Amistur, Diaz-Canel and Lis Cuesta Peraza, Alejandro Castro Espin
2026-06-05GAESA foreign-person wind-down deadline (OFAC limited non-targeting posture ends)

Ship-blocker guardrails

✓ No equity lane: no asset is investable_us=true. U.S. participation is remittance/payment support only.
✓ No Support CTA anywhere on Layer-2 / state / JV / Restricted-List / SDN / confiscated assets.
✓ OFAC SDN + Cuba Restricted List + CPAL screening on every counterparty (auto cross-referenced here).
✓ Recipient = independent private entity ≤100 employees, non-regime, documented.
✓ Settlement path proven to avoid GAESA / state banks / FINCIMEX.
✓ No confiscated-property (Helms-Burton) nexus on any supported deal.
✓ Support routed only through OFAC-authorized channels (§515.570 / §515.578 / §515.542); OFAC counsel sign-off.
✓ Disclosures on /invest and every opportunity page.
✓ Zero payments or inducements to officials or regime entities (FCPA + sanctions).

Research and product design, not legal advice. Stand up the fund and any Cuba-facing transaction only with OFAC sanctions counsel and securities counsel. Screening must use the live OFAC/State sources — the lists baked into this site are dated snapshots (see Data).