Step-by-step guide · 2026-10-07

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.

Who this is for: U.S. donors, diaspora giving circles, parishes and small foundations

Donating to Cuba is authorized under §515.570 — (b) for individuals, (c) for religious organizations, (g)(1)–(2) for independent humanitarian and civil-society organizations — and the September 30, 2026 rule did not change that. The constraint is the recipient, not the amount: a church, an independent charitable organization or an individual — never the Cuban state, a Restricted List entity or a prohibited official. Donations through QvaPay reach the recipient without a QvaPay deduction (the peer's exchange spread is borne by the recipient) but are not tax-deductible; for a receipt, give through a U.S.-registered nonprofit's own site.

Is it allowed? The legal authority

Allowed · Sept 30, 2026 rule§515.570(b) was not amended. The recipient organization is screened against the Restricted List and the SDN list, and no Restricted List entity may collect, forward or receive the remittance (§515.421(a)(7); §515.209).

You (U.S. donor)

Screened rail

Church, charity or individual (Cuba)

U.S. party — payer, exporter, merchantQvaPay — screened, U.S.-held balanceCuban private party — person, entrepreneur, MIPYMENon-U.S. party — supplier, forwarder, bankBlocked or prohibited step⇢ leg outside QvaPay, evidenced by documents

Who sends: A U.S. person, 18 or older, donating to a church, religious organization or independent charitable organization in Cuba, or making a donative remittance to an individual.
Who receives: A religious or charitable organization in Cuba, or an individual in Cuba — never a prohibited official of the Government of Cuba or a prohibited member of the Cuban Communist Party (§§515.337, 515.338), and never an entity on the Cuba Restricted List.

Legal basis

31 CFR §515.570(b) donative remittances to individuals · §515.570(c) remittances to religious organizations in Cuba, in support of religious activities · §515.570(g)(1)–(2) remittances to independent humanitarian and civil-society organizations. §515.566 covers religious travel and does not authorize donations.

Controls

Purpose attestation (Donation) on the funding row; identity verification of the recipient (organization: registration document and the person who controls the account); Sanctions Sentinel on both parties; BSA recordkeeping of sender and recipient details at $3,000 and above (31 CFR 1010.410(e)).

Donations routed to organizations through QvaPay are not tax-deductible and no charitable receipt is issued; to donate to a U.S.-registered nonprofit for a receipt, give through the organization's own site (see /nonprofits).

The Cuban-side balance: since September 30, 2026 OFAC no longer authorizes U.S. banking institutions — which OFAC reads to include registered money transmitters (FAQ 1090) — to maintain accounts for independent Cuban entrepreneurs (§515.584(h)(2) removed; FAQ 1273). A balance for a person in Cuba is held to receive an authorized U.S. payment and remit it to Cuba (§515.584(h); FAQ 748). Whether a balance may be funded from inside Cuba by peer conversion, or spent from Cuba on a U.S. exporter or provider, is QvaPay's legal position, submitted to OFAC in Case CU-2025-1426925-1 and not confirmed.

Primary sources:31 CFR §515.570 ↗

Step by step

1Pick the recipient. For an organization, QvaPay verifies its registration document and the person who controls the account; for an individual, their identity.
2Fund your balance and mark the purpose as Donation on the funding row.
3Sentinel screens the organization, its controller and any intermediary against the SDN List and the Cuba Restricted List, with a signed attestation and open-source review on the §515.337/.338 definitions.
4Send in QUSD; the recipient converts peer-to-peer with a verified peer.
5For a tax receipt, use the Nonprofits directory and give on the organization's own website instead.

How QvaPay executes it

See how QvaPay does itP2P leg terminates in Cuba

You (U.S. donor) — bank, card or crypto

fund

QvaPay's U.S. bank (wire/card) or USDC reserve (crypto) · QUSD minted

credit

QUSD credited · transferred to the verified church, charity or individual

sell

P2P trader buys the QUSD with their own pesos

pay out

Recipient paid in CUP, or spends QUSD directly

What QvaPay never touches

No state entity, government program or Cuba Restricted List entity — however humanitarian the label.
No Cuban bank and no state remittance processor in the chain.
No tax receipt — QvaPay is not a charity; for a deduction give through a U.S.-registered nonprofit's own site.

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: Donor screened at funding; the organization's registration document and the person who controls its account verified; recipient, controller and trader screened against SDN, the Cuba Restricted List and §515.337/338 before release.

Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →

What you need

✓Organization's registration document (for institutional recipients).
✓ID of the person controlling the recipient account.
✓Purpose attestation: Donation.

What you cannot do

✕Donate to a state entity, a Restricted List entity or a government-run program — however humanitarian the label.
✕Claim a U.S. tax deduction for a donation routed through QvaPay.
✕Donate to a prohibited official or Party member (§515.337, §515.338).
✕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).

Common questions

Can I donate medicine or food instead of money?+

Yes, but that is an export, not a remittance: gift parcels and humanitarian donations follow 15 CFR §740.12 (License Exception GFT) and §515.533. See the assisted-purchase guide for goods bought in the United States and shipped to an individual.

Is the Catholic Church in Cuba a permitted recipient?+

Yes — remittances to religious organizations in Cuba in support of religious activities are authorized by §515.570(c) (not §515.566, which covers religious travel). The organization must be independent of the Government of Cuba and the Party and not on the Cuba Restricted List; the account controller is identity-verified and screened.

Ready to do it?

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 ↗Contact →All permitted flows →

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).