⚠ COMPLIANCENot investment advice. U.S. sanctions restrict Cuba investment to the licensed independent private sector. Every transaction is KYC'd, OFAC-SDN & Cuba Restricted List screened, confirmed as an independent private entity (≤100 employees), and subject to OFAC counsel. No money flows to state, JV, GAESA, Restricted-List or confiscated-property counterparties.

Layer 1 · Compliant today

Support Cuba's entrepreneurs now

The legal lane for U.S. persons today is support, not equity: OFAC-authorized remittances and payments to the licensed independent private sector — Cuban-owned MIPYMEs of ≤100 employees, not regime- or Party-linked — routed through QvaPay wallets. We deliberately do not take equity stakes in Cuban entities; that keeps participation squarely inside the general licenses below.

This is the hopeful part: every dollar goes straight to a Cuban entrepreneur building something real — a paladar, a farm, a workshop — and lands on the ground the same day. You don't have to wait for the island to open to start backing its people.

Authorized support

Remittances & payments under OFAC general licenses (§515.570 / §515.578 / §515.542) — not securities, not equity. No card or bank credentials touch this site.

Screening

Every recipient is KYC'd, OFAC-SDN & Cuba Restricted List screened, and confirmed an independent private entity (≤100 employees), reviewed by OFAC counsel.

QvaPay wallets

Funds land on the ground via QvaPay wallets (QUSD) — never through Cuban state banks, FINCIMEX, GAESA or any Restricted-List counterparty.

Support via QvaPay

Participation is OFAC-authorized remittance/payment support to vetted private entrepreneurs, with OFAC counsel sign-off — not an equity offering.

Support via QvaPay →Read the compliance posture →

Supportable now

Agriculture · Granma/Santiago

Sierra Maestra Coffee Highlands

Smallholder/private revival; specialty-export thesis

🟢 Private✅ Supportable via QvaPay

Tourism · La Habana

Old Havana (Habana Vieja) Restoration

Private hospitality (restaurants, B&Bs, boutique) = Layer-1 deal flow

🟢 Private✅ Supportable via QvaPay

Tourism · Sancti Spíritus

Trinidad (Heritage Tourism Town)

Strong private-sector hospitality deal flow

🟢 Private✅ Supportable via QvaPay

Private sector · La Habana

Havana MIPYME Cluster

SUPPORTABLE NOW via QvaPay (remittances/payments) — diaspora/foreign equity allowed since Mar 18 2026; deploy via QvaPay wallets

🟢 Private✅ Supportable via QvaPay

Private sector · Pinar del Río

Pinar del Río Private Farms

SUPPORTABLE NOW via QvaPay (remittances/payments) — private agricultural MIPYMEs

🟢 Private✅ Supportable via QvaPay

Private sector · Havana / Camagüey / Cienfuegos

Cuba Emprende Graduate Network

SUPPORTABLE NOW via QvaPay (remittances/payments) — pre-trained, high-intent MIPYMEs; activation via Slyk-powered Upside Hub + QvaPay wallet

🟢 Private✅ Supportable via QvaPay

The legal basis

General licenses that authorize this private-sector support lane:

515.340

Not a stand-alone license — defines 'independent private sector entrepreneur', the eligibility class the other private-sector GLs run through. Excludes prohibited Cuban government officials and Communist Party members; caps qualifying private businesses/cooperatives at 100 employees.

Establishes who counts as legitimate private sector. A MIPYME or its owners must fit this definition to be a permissible counterparty, keeping the activity clear of GAESA / state-controlled (CRL) entities.

515.582

Import into the U.S. of goods and services produced by independent Cuban entrepreneurs (per the State Department's 515.582 List), including all payments necessary, with documentary proof of independent status.

Primary legal lane for buying from / paying Cuban private-sector producers (MIPYMEs). Supports remittance- and payment-rail flows (e.g., QvaPay) tied to genuine private-sector goods/services rather than state entities.

515.542

Mail and telecommunications transactions and payments involving Cuba, including internet connectivity and contracts with providers serving individuals in Cuba.

Underpins the connectivity and payment-messaging layer that fintech and digital private-sector services rely on; legitimizes paying for telecom/data services that QvaPay/MIPYME operations depend on.

515.578

Export/reexport to Cuba of internet-based communication and supporting services (incl. software design, IT management, cloud services) and import of Cuban-origin software.

The lane for software, fintech app delivery, and cloud/IT services to and from Cuban private-sector developers — directly relevant to a digital wallet / fintech (QvaPay-type) and to investing in MIPYME tech ventures.