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.
Who this is for: Anyone in the United States keeping someone in Cuba connected
Keeping a particular person in Cuba connected is lawful two ways. §515.542(c) lets a U.S. person pay the Cuban carrier directly for a specific individual's service (OFAC FAQ 790). QvaPay does not use that route: your transfer is a family or donative remittance under §515.570, forwarded under §515.572(a)(3), and a verified peer in Cuba completes the top-up locally with their own pesos — so the U.S. leg never settles with the state carrier.
Is it allowed? The legal authority
- Who sends
- A U.S. person sending value so a particular Cuban's mobile, data or Nauta service stays funded — a §515.570 remittance, screened; the top-up is completed in Cuba by a peer.
- Who receives
- The Cuban user whose line or account is topped up — not a prohibited official or Party member. Direct payment to the carrier for a particular Cuban's service is separately authorized by §515.542(c); the rail does not use it and never settles with ETECSA.
The U.S. sender's transfer is a family or donative remittance (31 CFR §515.570(a)/(b)), forwarded by QvaPay under §515.572(a)(3); the top-up itself is completed in Cuba by a Cuban peer. Paying the Cuban carrier directly from the United States for a particular individual's service is separately authorized by §515.542(c) (OFAC FAQ 790) — QvaPay does not use that route; an entity that does must notify OFAC and report under §515.542(g). Internet connectivity is a telecommunications service under §515.542(h).
Step by step
- 1Verify your identity on QvaPay and fund your balance.
- 2Enter the recipient's phone or Nauta account; Sentinel screens the account holder.
- 3Send the amount in QUSD to the recipient's QvaPay balance.
- 4A verified peer in Cuba — an account holder, screened, with volume limits — completes the recharge in CUP from their own funds; the recipient's line is credited.
- 5Keep your receipt for ten years (31 CFR §501.601); QvaPay retains the transaction record for at least five years as the BSA requires (31 CFR §1010.430).
See how QvaPay does itP2P leg terminates in Cuba
- QvaPay never pays the state telecom operator — no account, no settlement relationship, no funds sent.
- QvaPay has no relationship with any Cuban bank or state payment processor.
- A P2P transaction, not a withdrawal through the fiat door: the QUSD moves to the peer, who buys the service locally with pesos already in Cuba.
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: Sender and user screened; §515.337/338 attestation on the user; internal limits on top-up amounts; the peer is a verified account holder, screened.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
- ✓Sender identity verification.
- ✓Recipient's phone number or Nauta account and name.
- ✕Pay ETECSA, or any state carrier, directly from the United States through the rail.
- ✕Top up an official or Party member excluded under §515.337/.338.
- ✕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).
Damaris stays connectedcomposite illustration
Damaris books every client on WhatsApp. When her line goes dead her week stops, so her sister Yolanda keeps it funded: $30 covers the mobile line and two months of Nauta data.
The chain matters more than the amount. Yolanda funds the balance. The balance sits in Damaris's verified account. Damaris requests a top-up withdrawal. Leandro Pupo pays for the line and the Nauta account locally, in pesos, from his own funds. The service activates on Damaris's phone. Leandro receives the dollar balance.
Telecommunications service to particular individuals in Cuba is expressly authorized. §515.542(c) reaches activation, usage and pre-paid fees; §515.578 reaches internet-based services; and where the value simply arrives as support for Damaris, §515.570 applies. The authorization exists even though the provider is state-owned.
QvaPay does not use it. It holds no account with the telecom operator, sends it no funds, and has no settlement relationship with it. A private Cuban peer buys the service with money already in Cuba. Damaris is screened, as is Yolanda, and neither is a prohibited official or Party member — the guardrail this flow turns on.
No Cuban state bank, no regime payment processor, and no payment of any kind from QvaPay to the state telecom operator. QvaPay holds no account with it. The peer bought the service locally with his own pesos.
- Identity verification and screening on sender and recipient
- SDN and Cuba Restricted List screening both ends
- Prohibited-official and Party-member filter
- Purpose attestation
- The peer is a verified account holder, screened
- Internal limits on top-up amounts
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
Why not just use a recharge site?+
Most recharge sites pay ETECSA, a state entity, from abroad — which §515.542(c) authorizes for a particular individual's service, with OFAC notification and reporting duties for the paying entity (§515.542(g)). QvaPay's design is different by choice, not by requirement: the U.S. leg is a remittance and never touches the state carrier.
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).