New sanctions · Sept 30, 2026What changed, and how QvaPay keeps the lawful lanes open →
Permitted Fund FlowsSee the flows →
QvaPay SentinelTry Sentinel →
New on The WorldListen →
New Cuba
⚠ COMPLIANCENot legal, tax or investment advice, and not authorization for any transaction. U.S. sanctions (31 CFR Part 515) prohibit investment or equity in any Cuban business; nothing here is a determination that a transaction is lawful. Structure anything Cuba-facing only with qualified OFAC sanctions counsel and screen every party with QvaPay Sentinel.Primary sources: OFAC Cuba Sanctions · 31 CFR Part 515 (CACR) · OFAC Cuba FAQs · Cuba Restricted List
QvaPay guides · English & Spanish

How to send, pay, export and support in Cuba — one guide per fund flow

Each guide answers one question: what is allowed, under which authority (with the primary source), and how to do it step by step in QvaPay. The guides read the same data as the fund-flow diagrams, so they cannot drift from them.

After September 30, 2026

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.

What closed

U.S. banks may no longer hold accounts for Cuban entrepreneurs, and existing ones must be blocked (§515.584(h)(2) withdrawn; OFAC FAQ 1273).

How QvaPay solves itPartly pending with OFAC

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).

Processing authorized payments: allowed. Holding and spending a balance in Cuba: QvaPay's position, pending with OFAC.

Every fund flow →
What closed

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).

How QvaPay solves itPartly pending with OFAC

The Cuban buyer pays a U.S. seller directly from QvaPay, against the invoice, the export authorization and the shipping documents. No third-country bank, no cash processor in Havana.

The export: allowed (§515.533). The payment from the QvaPay balance: QvaPay's reading, pending with OFAC.

The Florida route →
What closed

A Cuban business may no longer pay a supplier outside the United States for foreign goods or services through U.S. rails.

How QvaPay solves itPartly pending with OFAC

QvaPay points Cuban buyers to U.S. manufacturers and distributors — U.S.-made goods first — and QvaPort (in formation) will consolidate their orders in Florida.

Sales from U.S. sellers: allowed. Payment from the QvaPay balance: pending with OFAC.

Why, and what works instead →
What closed

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.

How QvaPay solves itQvaPay control

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.

A control QvaPay applies to every payment.

QvaPay Sentinel →
What closed

Remittances were not cut — but every leg is now screened for Restricted List entities, which rules out the state remittance companies and state banks.

How QvaPay solves itAllowed

Dollars from the United States arrive in seconds. The family converts with a verified peer at the market rate, never at the official rate and never through a state channel.

Allowed (§515.570), forwarded under §515.572(a)(3). The peer conversion is part of QvaPay's request to OFAC.

Send a remittance →
What closed

With entrepreneur accounts frozen, paying a Cuban freelancer through a bank got slower and riskier.

How QvaPay solves itAllowed

U.S. companies pay independent Cuban contractors in dollars, each on their own invoice, through QvaPay.

Allowed for U.S. payers (§515.582; §515.340(b)). Not employment.

Pay a contractor →

“Pending with OFAC” means QvaPay's position in its request for interpretive guidance (Case CU-2025-1426925-1), not yet confirmed by OFAC. QvaPay, Inc. is a FinCEN-registered money services business, not a bank. Not legal advice.

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How to send a remittance to Cuba in 2026

Family, donative and private-sector support remittances under 31 CFR §515.570 — who can send, who can receive, and the five steps from a U.S. card to CUP in Cuba.

U.S. persons sending money to family, friends or an entrepreneur in Cuba
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How to donate to a church, charity or person in Cuba

Giving to individuals (31 CFR §515.570(b)), to religious organizations in Cuba (§515.570(c)) and to independent humanitarian and civil-society organizations (§515.570(g)) — with the screening the rule now requires.

U.S. donors, diaspora giving circles, parishes and small foundations
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How to top up a phone or Nauta account in Cuba

Keeping a particular Cuban's mobile, data or Nauta service funded: the U.S. leg is a §515.570 remittance forwarded under §515.572(a)(3); a Cuban peer completes the top-up locally, so no payment reaches ETECSA from the United States.

Anyone in the United States keeping someone in Cuba connected
☁️

How a Cuban can pay for U.S. online services — hosting, domains, software

Internet-based services from U.S. providers are authorized exports under 31 CFR §515.578; the payment is ordinarily incident under §515.421. How a Cuban user — or a U.S. friend buying for them — pays.

Cuban developers and freelancers; U.S. persons buying tools for someone in Cuba · Partly pending with OFAC
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How to buy goods in the United States and send them to someone in Cuba

Personal and family-use items under BIS License Exception SCP (15 CFR §740.21(b)(2)) and 31 CFR §515.533 — bought from a U.S. merchant, shipped from the United States, paid through a screened rail.

Relatives abroad; Cubans buying from U.S. stores with their own balance (pending with OFAC) · Partly pending with OFAC
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How to buy goods and services from Cuban entrepreneurs

Importing what independent Cuban entrepreneurs make under 31 CFR §515.582 — the State Department's exclusion list for goods, no exclusions for services, and how the U.S. buyer pays.

U.S. buyers, retailers and clients of Cuban makers and studios
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How to pay independent Cuban contractors

Paying independent Cuban developers, designers and consultants from a U.S. business or client under 31 CFR §515.582 — each contractor an independent entrepreneur under §515.340, on their own invoice, from a verified business account. Not employment, not payroll.

U.S. startups, agencies and individual clients contracting Cuban talent
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How to export goods from the United States to Cuba's private sector

Selling to a Cuban MIPYME under 31 CFR §515.533 and BIS License Exception SCP (15 CFR §740.21(b)(1)) — classification, the March 2026 bank condition, the EEI, and how the MIPYME pays the U.S. exporter.

U.S. exporters, distributors and manufacturers' U.S. subsidiaries · Partly pending with OFAC
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Why a Cuban business can no longer pay a foreign supplier through U.S. rails — and what works instead

On September 30, 2026 OFAC withdrew 31 CFR §515.584(h)(2). A U.S. bank or payment platform may no longer process a payment from a Cuban enterprise's funds to a supplier outside the United States. The route that remains — buying from a U.S. manufacturer or distributor as a §515.533 export, consolidated in Florida — rests in part on QvaPay's legal reading, pending with OFAC.

Cuban MIPYMEs and the foreign suppliers that sold to them through Panama, Mexico or Hong Kong · Partly pending with OFAC
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How to sell to Cuba’s private sector from Florida: U.S. manufacturers and distributors

U.S. manufacturers and U.S. distributors sell to Cuban MIPYMEs as U.S. exporters under 31 CFR §515.533 and a Commerce authorization; the Cuban buyer pays the U.S. seller from its QvaPay account, and QvaPort (in formation) will consolidate in Florida. U.S.-made goods first. The ten steps, who does what, what cannot be done, and the document chain.

U.S. manufacturers, U.S. distributors and exporters, Cuban MIPYMEs and cooperatives · Partly pending with OFAC
In preparation
  • 🚀How to take part in Cuba's third act as a startup nation — notify me