Step-by-step guide · 2026-10-07

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.

Who this is for: Relatives abroad; Cubans buying from U.S. stores with their own balance (pending with OFAC)

Partly pending with OFAC — read this first

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.

Goods bought from a U.S. merchant and shipped from the United States to an individual in Cuba for personal or family use are an authorized export — §740.21(b)(2) on the Commerce side, §515.533 on the Treasury side — and the payment is ordinarily incident to it. The seller is a U.S. merchant shipping from the United States; what matters is that they leave the United States under a Commerce authorization. The use test decides the lane: goods for a business follow the export guide instead.

Is it allowed? The legal authority

Partly pending with OFACA U.S. payer: allowed. Payment from a Cuban user's QvaPay balance: QvaPay's position, pending with OFAC (Case CU-2025-1426925-1). Allowed for goods exported from the United States — a U.S. manufacturer or distributor selling from the United States — under SCP §740.21(b)(2) and §515.533, neither touched by the OFAC rule. Payments to merchants outside the United States for foreign-made goods are prohibited since September 30, 2026 and not processed. BIS's 4 March 2026 condition reaches only (b)(1).

Payer (U.S., abroad or Cuba)

Screened rail

U.S. merchant (ships from the U.S.)

Courier ⇢ 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 payer in the United States, abroad or in Cuba, screened, buying eligible items — EAR99 or controlled only for anti-terrorism — from a merchant in the United States that exports them for delivery to an individual in Cuba. The seller is a U.S. manufacturer or distributor selling from the United States, U.S.-made goods first. A merchant outside the United States selling foreign-made goods is not paid.
Who receives: The individual in Cuba receiving the items for personal or family use — screened against the excluded officials at §740.21(d)(4)(ii)–(iii). The use test decides the lane: goods for a business are a different flow with different conditions.

Legal basis

BIS License Exception SCP 15 CFR §740.21(b)(2) (personal and immediate-family use) · 31 CFR §515.533 (export from the United States; payment ordinarily incident under §515.421) — the 4 March 2026 suspension reached (b)(1) only.

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:15 CFR §740.21 ↗31 CFR §515.533 ↗

Step by step

1Choose eligible items: EAR99 or controlled only for anti-terrorism reasons — household goods, clothing, phones, laptops, medicine for personal use.
2Buy from a merchant in the United States that ships to Cuba or to a Cuba-bound courier; the merchant is the exporter.
3Pay through QvaPay: the payer — identity-verified wherever located; a payer outside the United States and Cuba also gives proof of address and source of funds — funds the purchase; Sentinel screens payer, recipient and merchant, and QvaPay records the payer–recipient relationship. Repeated purchases of the same goods to the same or related recipients are treated as commercial stock, which belongs in the export flow.
4The merchant files the EEI in AES for every shipment to Cuba regardless of value (gift parcels under License Exception GFT excepted) and ships; a courier may consolidate and deliver to the individual in Cuba. The sale is to the individual in Cuba who will use the items (§740.21(b)(2)); when a relative in the United States buys the goods and sends them as a gift, the export usually runs under License Exception GFT (§740.12) instead. A buyer who resells or buys for third parties is outside both.
5The recipient keeps the invoice — Cuban customs applies its own personal-import allowances and duties.

How QvaPay executes it

See how QvaPay does itP2P leg wherever the QUSD was sourced

Payer's QUSD — an identity-verified payer: funded through the fiat door (a payer outside the U.S. and Cuba also gives proof of address and source of funds), or held by a Cuban user (bought from a peer, or received as a remittance, payment or donation)

withdraw

QvaPay's U.S. bank pays the merchant · QUSD burns at par

pay

U.S. merchant → courier from the U.S.

Individual in Cuba (personal use)

What QvaPay never touches

The money never enters Cuba — only the goods do, by courier to a private address.
No Cuban bank; no state importer or distributor in the path.
The personal-use test at the point of sale is what keeps this in §740.21(b)(2), untouched by the March 2026 suspension.

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: Payer and named end consumers screened, incl. the §740.21(d)(4)(ii)–(iii) excluded-official check; merchant and forwarder screened and the merchant confirmed U.S.-based; invoice and delivery record retained. Merchants outside the United States selling foreign-made goods are refused.

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

What you need

✓Merchant invoice naming the individual recipient in Cuba.
✓Recipient identity (carnet) for screening.
✓Courier tracking / proof of export from the United States.

What you cannot do

✕Send goods a business will resell — that is the export flow, with its own conditions.
✕Send to an official excluded under §740.21(d)(4) or a prohibited Party member (the Politburo, §515.338).
✕Ship from a third country: a U.S.-owned company abroad may not sell non-U.S. goods to Cuba directly (§515.533(a)(2)).
✕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).

How it looks in practice

Norma's laptop and glucose monitorcomposite illustration

Norma buys two things for Matanzas: a refurbished laptop for Yunior, $430, and a glucose monitor with six months of test strips for his grandmother Zoraida, $180.

The glucose monitor is EAR99. The laptop is mass-market encryption, 5A992.c, controlled only for anti-terrorism — still eligible. Both are bought from a merchant in Miami, which exports them through a courier to the family's door. Since 30 September 2026 QvaPay would not pay a merchant outside the United States for foreign-made goods; the same purchase from a shop abroad would be refused.

The authority is BIS License Exception SCP at 15 CFR §740.21(b)(2) — items sold directly to individuals in Cuba for their personal use or their immediate family's personal use — with 31 CFR §515.533 authorising the payment ordinarily incident to that export. (b)(2) does not require shipment directly to the individual, so a courier's consolidation is fine, provided the items are ultimately destined for Yunior and Zoraida for personal use. They are, and the file says so.

Two checks decide this one. Yunior and Zoraida were screened against the excluded officials at §740.21(d)(4)(ii)–(iii). And the use test was applied at the point of sale: personal and family use, not stock for a business. That is what puts this in (b)(2) rather than (b)(1).

The March 2026 BIS suspension does not reach this transaction. It was applied to (b)(1) only.

Where the money did not go

No Cuban state bank and no regime payment processor. No foreign funds were deposited into any Cuban bank at any point, and no Cuban state importer or distributor stood in the path — the courier delivered to a private address.

Controls shown

Identity verification and screening on the payer and both named end consumers; a payer outside the U.S. and Cuba also gives proof of address and source of funds
SDN and Cuba Restricted List screening
§740.21(d)(4)(ii)–(iii) excluded-official screen on the recipients
Item classification recorded as EAR99 / AT-only
The merchant's personal-use determination (the (b)(2) lane) recorded, with the recipient's attestation
U.S. merchant and forwarder screened; merchant confirmed U.S.-based
Commercial invoice and delivery record retained

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

Do foreign-made goods qualify?+

U.S.-made goods come first. Allied brands qualify when a U.S. distributor sells them from its own U.S. inventory and exports them under the same License Exception SCP as U.S.-made goods; QvaPay does not pay for a foreign factory’s sale routed through the United States.

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).