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.
Who this is for: Cuban developers and freelancers; U.S. persons buying tools for someone in Cuba
A U.S. person paying is allowed. A person in Cuba paying from their own QvaPay balance, and funding that balance by peer conversion, is QvaPay's legal position, submitted to OFAC (Case CU-2025-1426925-1) and not yet confirmed. Do not rely on this page as authorization; have your own counsel confirm it.
A U.S. provider may lawfully sell a domain, a virtual server, cloud storage or a software subscription to a Cuban developer, and a U.S. platform may process the payment: §515.578(a) authorizes the export of internet-based services to Cuba, and OFAC FAQ 756 confirms a payment platform may process the payment as a transaction ordinarily incident to that export. Downloadable apps and software are items, not services, and move under BIS License Exception SCP (§740.21) instead. The 2026 amendment did not change §515.578(a); every provider and processor in the path is still screened, because indirect transactions with Cuba Restricted List entities are now prohibited (§515.209).
Is it allowed? The legal authority
- Payer
- Most often the Cuban user, spending their own balance on an internet-based service from a U.S. provider — a domain, a virtual server, cloud storage, a VPN, a software subscription, an app — or a U.S. person buying it for someone in Cuba. §515.578(a) authorizes the export of internet-based services from the United States or by a U.S. person (web hosting not for the promotion of tourism; not to prohibited officials). An eSIM or data plan from a U.S. carrier rides §515.542. Since September 30, 2026 the rail does not pay foreign providers, foreign top-ups or gift cards. Top-ups of Cuba's own state operator are a different flow — Prepaid top-up in Cuba — completed by a peer, not a provider.
- Delivered to
- Individuals in Cuba (the service is delivered to them) — screened, not a prohibited official or Party member.
31 CFR §515.578(a) exportation of internet-based services by U.S. providers · §515.542 telecom from U.S. carriers · payment under §515.421 · downloadable software: BIS License Exception SCP §740.21 (EAR99, or mass-market 5D992 controlled only for anti-terrorism)
Step by step
- 1The payer funds a QvaPay balance — the Cuban user from their own receipts or QUSD bought on the P2P market, or a U.S. person buying for them.
- 2Request the payment to the U.S. provider from inside QvaPay, attaching the invoice or order.
- 3QvaPay checks the service is within §515.578 (internet-based communication services and the hosting, domains, cloud and software-design services that support them, §515.578(a)) and screens payer, beneficiary and provider.
- 4QvaPay pays the provider from its U.S. account as agent for the named Cuban user: the order is placed in the user's name and the provider is informed that the service is delivered to Cuba under §515.578.
- 5Downloadable software to Cuba follows BIS License Exception SCP (15 CFR §740.21) for EAR99 or anti-terrorism-only items.
See how QvaPay does itP2P leg wherever the QUSD was sourced
- No money enters Cuba — only the code or service does, over the internet.
- QvaPay has no relationship with any Cuban bank or state payment processor.
- Web hosting is checked for the tourism-promotion exclusion before the payment clears.
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: Account holder screened; every provider screened and confirmed U.S.-based, not only the customer; item classification recorded (EAR99 or 5D992) where software ships. Foreign providers, foreign top-ups and gift cards are refused.
An assisted purchase of a digital service from a U.S. provider: QvaPay coordinates the payment and the provider delivers, like a merchant shipping a good. Since 30 September 2026 providers outside the United States are not paid. Prepaid services of Cuba's own state operator are not bought this way — they are Prepaid top-ups in Cuba, completed by a peer. The P2P leg is wherever the QUSD entered the user's hands; it does not change how the purchase executes.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
- ✓Provider's invoice or order confirmation.
- ✓Payer and beneficiary identity verification.
- ✓Declared use: individual or independent private-sector activity.
- ✕Buy services for a state entity, a Restricted List entity or a prohibited official.
- ✕Pay a non-U.S. provider from a Cuban enterprise account — that is an import payment to a foreign supplier, prohibited since September 30, 2026.
- ✕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).
Alejandro's hosting, domain and softwarecomposite illustration
Alejandro writes inventory software for three private shops in Havana. He is paid in pesos and needs to buy in dollars: a domain, a virtual server, and a design-software subscription. Together, $148 a year.
He funds his QvaPay balance the way most Cuban account holders do — by selling pesos to a peer, Marisleidy Ortega, at the morning rate. QvaPay pays the three U.S. providers — a domain registrar, a cloud host and a design-software maker — from its U.S. account. The service is delivered to him over the internet. Since 30 September 2026 QvaPay would not pay a provider outside the United States.
§515.578(a) authorises the export of internet-based services to Cuba: web hosting, domain registration, cloud services, software design and collaboration tools among them. The payment is ordinarily incident under §515.421, and the design software rides BIS License Exception SCP at 15 CFR §740.21 as mass-market software, 5D992, controlled only for anti-terrorism.
One condition applies squarely here. Web hosting is authorized provided it is not for the promotion of tourism. Alejandro's site is a portfolio and a client login. It sells nothing to visitors, advertises no accommodation, and was checked on that specific point before the payment cleared.
All three providers were screened and confirmed U.S.-based, not only the customer.
No Cuban state bank and no regime payment processor. The balance was funded inside Cuba by a private peer buying pesos, not by a wire from abroad into any Cuban institution.
- Identity verification and screening on the account holder
- SDN and Cuba Restricted List screening on the customer and on all three providers, each confirmed U.S.-based
- Prohibited-official and Party-member filter
- Tourism-promotion check on the hosting service
- Software classification recorded (EAR99 or 5D992, anti-terrorism only)
- 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 a Cuban MIPYME pay for a U.S. SaaS subscription?+
Yes — §515.578(a) covers services to individuals and independent private-sector entrepreneurs; the enterprise and its owners are screened like any payer.
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).