Compliance
A U.S. person cannot wire money into Cuban state infrastructure, and no general license lets a U.S. person take equity in a Cuban MIPYME. The CACR frames private-sector support as remittances (§515.570, incl. (g)(3) support for independent private sector entrepreneurs) plus narrower import and internet/telecom lanes. This site enforces that line in code and copy: no equity buttons, no state-asset money path, and no claim that any transfer is authorized. See how the support lane works — or see how QvaPay does it.
The compliance engine that decides whether a Support affordance may appear — and the rails it rides.
The lines this site is built never to cross — no equity, no state-asset money path, screened counterparties.
Two practical checklists for the 2026 secondary-sanctions program — steering clear, and PYME diligence.
Official U.S. Cuba sanctions actions, verified and linked to the Federal Register.
The statutes, regulations and lists behind every flag on the atlas.
Enforced in code
A single compliance engine — not editorial judgment — decides what may appear.
A single compliance engine decides whether a Support affordance may appear on an asset page. It requires a cleared private-sector entry and a controlling counterparty that clears the Cuba Restricted List (236 entities in our snapshot), the OFAC SDN list, and the Prohibited Accommodations List (429 hotels in our snapshot). No asset may be marked investable_us=true — there is no equity lane — and the build fails on any record that tries. By design, no named businesses are listed as on-map Support targets; the lane is explained on /support rather than invented on the map.
The hard guardrails
The lines this site is built never to cross:
- ✓ No equity lane — no U.S. person takes an ownership stake in a Cuban enterprise under a general license. Support is remittance/payment-shaped, not securities.
- ✓ A Support CTA never appears on state, military, joint-venture, Restricted-List, SDN, or confiscated assets — only if the compliance engine marks an entry supportable (today: none on-map; the lane is explained on /support).
- ✓ Counterparties must be screened against the OFAC SDN list, the Cuba Restricted List, and (where relevant) the Prohibited Accommodations List.
- ✓ Eligible recipients are independent private sector entrepreneurs under §515.340 — not prohibited government officials or Party members (a class NSPM-5 directed OFAC to broaden).
- ✓ The rail should not run on Cuban state banking or regime-licensed payment-processor rails — QvaPay's CUP/MLC ↔ QUSD conversion leg — peer-to-peer by design, completed by independent Cuban P2P forex traders — is built for this, not a guarantee for every third-party path.
- ✓ EO 14404 (May 1, 2026; 91 FR 25061) layers a secondary-sanctions program over the CACR, but its Section 2(b) expressly preserves Part 515-licensed activity — so the private-sector GLs survive. The change: the blocked-persons pool expanded (energy, defense, metals & mining, financial services, security sectors + regime officials), and foreign banks risk secondary sanctions for facilitating transactions for blocked persons. Steer clear by screening every party and keeping recipients genuinely independent — never a designated/state/GAESA/MININT/MINFAR entity or anyone 50%+ owned by a blocked person (OFAC 50 Percent Rule).
- ✓ No supported activity should have a confiscated-property (Helms-Burton) nexus.
- ✓ Cite licenses by scope: §515.570 remittances (incl. (g)(3) private-sector support), §515.582 import-tied payments, §515.578 / §515.542 internet/telecom — not a fused 'pay anyone' GL.
- ✓ Compliance disclosures appear on the Support page and opportunity pages; nothing on this site authorizes a transaction.
- ✓ Zero payments or inducements to officials or regime entities (FCPA and sanctions).
Living with EO 14404
The 2026 secondary-sanctions program doesn't close the support lane — it expressly preserves Part 515 activity (§2(b)) — but it widens the danger zone. Two practical checklists:
- Stay inside a Part 515 general license — EO 14404 §2(b) expressly carves out Part 515-authorized activity.
- Recipient is a genuinely independent private-sector entrepreneur (§515.340), not owned or controlled by the Government of Cuba. EO 14404 blocks designated persons, not sectors — a private firm in energy, defense, metals and mining, financial services or security is not blocked by the order, but that is where designation risk concentrates, so screen it (and its counterparties) with extra care.
- Screen every party (names, entities, wallets) against the SDN and Cuba Restricted lists — EO 14404 designations land on the SDN list. Use QvaPay Sentinel.
- No designated person, and no counterparty 50%+ owned by a blocked person (OFAC 50 Percent Rule).
- Keep the rails clean — no Cuban state-bank or regime-processor path; the CUP/MLC ↔ QUSD conversion leg stays peer-to-peer.
- Mind the services perimeter: announcing the 20 August 2026 designations — ICAP's leadership and nine entities — the State Department warned that providing services to, or holding funds for, designated actors puts the provider at risk of designation. Re-screen counterparties after every tranche.
- Structure with OFAC counsel. Nothing here is a determination.
- Map beneficial ownership and verify identities.
- Confirm no owner is a prohibited official or Party member (§515.337–338) or an SDN — and that no blocked person holds 50%+.
- Confirm genuine independence (§515.340) with documentary evidence of independent status (§515.582).
- Screen every leg, not just the counterparty — no Cuba Restricted List entity as originator, intermediary or beneficiary (indirect transactions are prohibited since September 30, 2026).
- Screen all parties and wallet addresses (Sentinel); tier the diligence by risk (heavier for high-volume).
- Keep records — BSA recordkeeping at $3,000 or more (31 CFR 1010.410(e)); Travel Rule data (1010.410(f)) on outbound transmittals.
- Before an exporter payment is released: the exporter's invoice, EAR classification and declared authorization (SCP, AGR, CCD or licence), the EEI's ITN, the transport document, the exporter's compliance certificate, and invoice–payment–EEI matching. Full list in the FTZ guide.
Sanctions & Policy Watch
Official U.S. Cuba sanctions actions, each linked to its primary source: the Federal Register, or the issuing agency's own release when the notice hasn't published yet.
- Sep 30, 2026OFAC amends the CACR: indirect Cuba Restricted List transactions barred, U-turn and entrepreneur bank-account licenses withdrawn, professional-meeting and people-to-people travel ended91 FR 61741 · FR Doc. 2026-19973 · 31 CFR Part 515Federal Register →
- Sep 30, 2026OFAC issues the Cuba Sanctions Regulations (new 31 CFR Part 516) implementing E.O. 1440491 FR 61748 · FR Doc. 2026-19977 · 31 CFR Part 516Federal Register →
- Sep 17, 2026Designations: four nickel-sector enterprises at Moa and Nicaro and four FAR research and production enterprisesOFAC · State Dept · E.O. 14404 (FR notice pending)Federal Register →
- Sep 3, 2026OFAC designates Banco Exterior de Cuba, two CUPET arms and two nickel-sector firmsOFAC · State Dept · E.O. 14404 (FR notice pending)Federal Register →
- Aug 25, 2026Trading With the Enemy Act authorities continued for Cuba through 14 September 2027Presidential Determination 2026-21 · 91 FR 54935Federal Register →
- Aug 20, 2026State Dept sanctions ICAP leadership and nine regime entitiesState Dept release · E.O. 14404 (FR notice pending)State Dept →
- Aug 6, 2026Designations: UIM, Tecnotex, Tecnoimport, EMI Yuri Gagarin and DunaOFAC · State Dept · E.O. 14404 (FR notice pending)Federal Register →
- Aug 5, 2026State Department Cuba sanctions designations91 FR 50592Federal Register →
- Jul 31, 2026State Department Cuba sanctions designations (several notices)91 FR 48481–48484Federal Register →
- Jul 23, 2026Designations incl. the Mariel container terminal company and Coral Marítima; Cuba GLs 2–4OFAC · State Dept · E.O. 14404 (FR notice pending)Federal Register →
- Jul 13, 2026Designations incl. GEMAR, GECOMEX, ENETEC and ANTEXOFAC · State Dept · E.O. 14404 (FR notice pending)Federal Register →
- May 7, 2026First E.O. 14404 designations (GAESA, Moa Nickel) and Cuba General License 1OFAC · E.O. 14404 · FR Doc. 2026-15491Federal Register →
- May 1, 2026EO 14404 — Cuba secondary-sanctions program91 FR 25061Federal Register →
- Mar 4, 2026BIS suspends License Exception SCP §740.21(b)(1) for exports settling into Cuban-owned banksBIS guidance · EAR §740.2(b)BIS →
- Jan 29, 2026EO 14380 — Addressing threats from the Government of Cuba91 FR 5085Federal Register →
State Department designation notices are cited by their Federal Register publication where one exists, and by the Department's own release while it is pending; for the exact entities and individuals, consult OFAC's SDN list. Not legal advice.
The two-regime map (U.S. sanctions vs. Cuban law), every enabling general license with scope notes, Helms-Burton Title III/IV, and the 2025–2026 timeline live on the Legal page; confiscated-property risk is mapped on Claims.
Research and product design, not legal advice. Structure any Cuba-facing transaction only with OFAC sanctions counsel (and securities counsel if pooling capital). Screening must use the live OFAC/State sources — the lists baked into this site are dated snapshots (see Data).
Common questions
What are OFAC's Cuba regulations?+
The Cuban Assets Control Regulations (CACR), 31 CFR Part 515, administered by OFAC — plus the U.S. State Department's Cuba Restricted List and Prohibited Accommodations List. Together they broadly prohibit U.S. persons from investing in or transacting with the Cuban state.
What is the Cuba Restricted List and how do I check it?+
A U.S. State Department list of entities tied to Cuba's military and security services (largely the GAESA conglomerate) that U.S. persons generally may not transact with. The atlas cross-references it per asset; always confirm against the live State Department list.
Can I legally stay in a Cuban hotel?+
Not if it appears on the Cuba Prohibited Accommodations List — U.S. persons are barred from lodging at those properties. Many large hotels are GAESA/Gaviota-owned and listed.
Can a U.S. citizen travel to Cuba?+
Tourism is prohibited. OFAC authorizes travel only under specific general licenses — family visits, journalism, professional research, religious and humanitarian work, and “support for the Cuban people” among them; people-to-people educational travel ended in 2019 and NSPM-5 (2025) ordered the remaining categories tightened. Travelers must keep records and avoid Prohibited Accommodations List hotels.