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.
Who this is for: U.S. buyers, retailers and clients of Cuban makers and studios
A U.S. person may import goods and services produced by independent Cuban entrepreneurs — §515.582 authorizes the import and every transaction incident to it, including the payment. Goods must not fall on the State Department's §515.582 exclusion list (tobacco and alcohol, among others, are excluded); services carry no exclusions. The 2026 amendment did not touch this license.
Is it allowed? The legal authority
- Who sends
- A U.S. person, screened, paying to import goods or services from an independent Cuban entrepreneur — goods must not fall on the State Department's §515.582 exclusion list; services carry no such exclusions — §515.582 itself authorizes all transactions, including payments, necessary to import them.
- Who receives
- The independent entrepreneur or MIPYME that produced the goods/services — screened, with documentary proof of independent status (§515.340).
31 CFR §515.582 — imports of eligible independent-entrepreneur goods & services (incl. the payment)
Step by step
- 1Confirm the seller is an independent entrepreneur (§515.340): self-employment licence, MIPYME registration or cooperative papers — and no state, GAESA or prohibited-official ownership.
- 2Check the goods against the State Department's §515.582 list; services need no check.
- 3Agree the invoice in the entrepreneur's name; pay through QvaPay after Sentinel screens both parties.
- 4The entrepreneur receives QUSD and converts peer-to-peer with a verified peer; you receive the goods or services.
- 5Keep the invoice and the independence evidence for ten years (31 CFR §501.601) — §515.582 asks the importer to hold documentary proof.
See how QvaPay does itP2P leg terminates in Cuba
- The dollars are never remitted into Cuba — they stay in a U.S.-held balance until an independent Cuban peer buys them.
- QvaPay has no relationship with any Cuban bank or state payment processor.
- Excluded HTS goods (rum, tobacco, minerals, machinery, vehicles) are not processed; services carry no exclusions.
The CUP/MLC side of a peer trade is settled between the two peers outside QvaPay — in cash or through the peer's own Cuban bank account. QvaPay does not hold, move, see or certify that leg; it records only the QUSD side. Peers trade their own funds, declare their activity, are limited in volume against it and are reviewed when they exceed it; a peer located in the United States may not trade on the market. Crypto funding is accepted only in USDC from screened wallet addresses; inflows from unhosted wallets receive source-of-funds review, and the same $3,000 recordkeeping applies.
Screened: KYC/KYB on the MIPYME and every beneficial owner; §515.340 independent-status documentation; buyer and MIPYME screened both ends; trader screened.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
- ✓Entrepreneur's independence evidence (TCP licence, MIPYME registration).
- ✓Commercial invoice in the entrepreneur's name.
- ✓For goods: HS line and a check against the State §515.582 list.
- ✕Import excluded goods (State §515.582 list), anything produced by a state enterprise, or goods a state entity processed into a new name, character or use (OFAC FAQ 1178).
- ✕Pay a state intermediary, exporter or Restricted List entity anywhere in the chain.
- ✕Take equity in the entrepreneur's business — there is no equity general license.
- ✕Try to route around these rules — split payments, use a conduit, pay through an unidentified third party. Such attempts are refused and may be reported as the Bank Secrecy Act requires (31 CFR §1022.320).
Priya commissions Taller Almendarescomposite illustration
Priya commissions cover art and interior layout for three books: $2,400 to Taller Almendares, a four-person design studio in Havana.
This is an import — of a service, from Cuba to the United States — and §515.582 authorises all transactions, including payments, necessary to import goods and services produced by independent Cuban entrepreneurs. The studio's services fall outside the §515.582 List entirely — its exclusions are goods-only — and its independent status under §515.340 is documented: license, ownership structure, and both beneficial owners identified and screened. Dayana holds 55 percent, Rubén 45.
Two things the file records deliberately. First, the exclusions to this authority apply to goods only; services carry none. Second, nothing in this engagement touches an excluded Harmonized Tariff Schedule section — no rum, no tobacco, no minerals, no machinery, no vehicles. Those are excluded from import and QvaPay does not process them. (Coffee, once excluded, has been eligible since the State Department's 2016 update.)
Payment lands as a QvaPay balance in the studio's name. When the owners want pesos, Maikel Duarte buys the balance at the market rate and pays them from his own funds. The dollars never enter a Cuban bank. They stay in a U.S.-held balance until an independent Cuban buys them.
No Cuban state bank and no regime payment processor. The dollars were never remitted into Cuba at all — they stayed in a U.S.-held balance and were bought by a private Cuban peer, who paid the studio in pesos he already held.
- KYC/KYB on the studio
- Both beneficial owners identified and screened
- §515.340 independent-status documentation (services carry no §515.582 exclusions)
- SDN and Cuba Restricted List screening both ends
- HTS exclusion screen recorded on the goods question
- Purpose attestation and commercial invoice
- The peer is a verified account holder, screened
Composite illustration based on real QvaPay transaction patterns. Names, amounts and identifying details have been changed. Not a determination that any transaction is authorized.
Common questions
Can I import Cuban cigars or rum from a private producer?+
No. Tobacco and alcohol are on the State Department's §515.582 exclusion list regardless of who produced them.
Open QvaPay and follow the steps above. If you are a business, an exporter or an organization, write to us and we onboard you case by case.
QvaPay, Inc. is a FinCEN-registered money services business (MSB No. 31000329382692) providing payment services; it is not a bank. A QUSD balance is a payment obligation of QvaPay, Inc., held in the United States — not a bank deposit and not FDIC-insured. QvaPay forwards remittances under 31 CFR §515.572(a)(3) and processes authorized payments as transactions ordinarily incident under §515.421 (OFAC FAQ 756); the standing of balances held for persons in Cuba is among the questions put to OFAC in QvaPay's pending request for interpretive guidance (Case CU-2025-1426925-1).
This guide is general information, not legal advice and not a determination that any transaction is authorized. Rules change; the update date is above. Keep your own records for ten years (31 CFR §501.601).