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.
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U.S. banks may no longer hold accounts for Cuban entrepreneurs, and existing ones must be blocked (§515.584(h)(2) withdrawn; OFAC FAQ 1273).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).
Processing authorized payments: allowed. Holding and spending a balance in Cuba: QvaPay's position, pending with OFAC.
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 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 →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. 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 →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.
A control QvaPay applies to every payment.
QvaPay Sentinel →Remittances were not cut — but every leg is now screened for Restricted List entities, which rules out the state remittance companies and state banks.
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 →With entrepreneur accounts frozen, paying a Cuban freelancer through a bank got slower and riskier.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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