New sanctions · Sept 30, 2026What changed, and how QvaPay keeps the lawful lanes open →
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⚠ COMPLIANCENot legal, tax or investment advice, and not authorization for any transaction. U.S. sanctions (31 CFR Part 515) prohibit investment or equity in any Cuban business; nothing here is a determination that a transaction is lawful. Structure anything Cuba-facing only with qualified OFAC sanctions counsel and screen every party with QvaPay Sentinel.Primary sources: OFAC Cuba Sanctions · 31 CFR Part 515 (CACR) · OFAC Cuba FAQs · Cuba Restricted List
Product · Bouncer

QvaPay Bouncer AI Watches Every User, Every Transaction, All the Time

Our transaction monitor checks every account every day, restricts on a fail, and puts every case in front of our compliance officer.

Tim Parsa · Co-Founder & CCO, QvaPay · 19 May 2026 · 4 min read Subscribe

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QvaPay Bouncer AI Watches Every User, Every Transaction, All the Time

Every compliance program I built, at Todito Cash, Uphold, and Airtm, had people and vendors in the middle: one vendor for identity, another for screening, another for monitoring, and analysts clearing alert queues by hand. The program was only as good as its slowest handoff. With AI, Erich and I realized we could build our own, on our own flows.

What it does

Bouncer sweeps the whole ledger every day. It queries every account for structuring, velocity, rapid in-and-out, funnels, and counterparty spread, and checks each one against the purpose its owner declared. On a fail, it restricts the account and writes the case for our compliance officer, who decides. We tune its rules every week as new patterns show up.

FlowLegitimateBad actor, and what Bouncer does
RemittancesA daughter in Tampa sends $300 to her mother every two weeks.Twenty unrelated senders each send $499 to one account in a day. Funnel pattern: restricted, case opened.
Business paymentsA bakery pays its U.S. exporter against invoices.A "bakery" asks to pay a bank in a third country, with no goods behind it. Refused and reviewed by our compliance officer.
P2P forexPeers trade daily at the market rate.Two accounts trade back and forth to manufacture volume. Flagged for the compliance officer.
Contractor paymentsA studio pays four contractors monthly."Contractor payments" to fifty accounts opened the same week. Flagged before the second run.

A U.S. bank will sit behind a Cuba corridor only if it can see the corridor police itself. Bouncer and the compliance officer who reviews its cases let it see that.

Compliance technology built in the United States by a Cuban-American founder, under U.S. law, lets this corridor grow from an estimated $1.1–2 billion a year toward the Dominican Republic’s rate per person, five to nine times today.

Fund flows in this post

Bouncer screens every party in these flows, every time.

FlowHow we grow itU.S. tech meets Cuban talent
Remittances
Permitted · 31 CFR §515.570 (U.S. senders)
Marketing by use case to the diaspora in Miami and beyond; every sender and recipient screened.Diaspora dollars become working capital for families and the private businesses they start.
Assisted vendor payments
QvaPay's reading of §515.533/§515.421 · pending with OFAC
SkyMind will pay U.S. exporters by wire from QvaPay's U.S. bank; a Florida logistics hub shortens delivery.U.S. exporters sell solar panels, tools, and machines to Cuban private businesses.
P2P forex
Pending with OFAC · no authorization asserted
SkyMind matches orders and more screened traders join.Every trader is a small business: Cubans earn a spread connecting dollars and pesos.
Pay independent contractors
Permitted for U.S. payers · §515.582, §515.340(b); not employment
Sign U.S. companies that contract independent Cuban developers and studios; one onboarding per client.U.S. companies contract independent Cuban engineers and designers and pay each invoice in dollars.

The potential. Remittances into Cuba run an estimated $1.1–2B a year (2024; estimates vary). At the Dominican Republic’s rate per person, Cuba would receive about $9.8B, five to nine times today. That is the market QvaPay is built to serve.

How big this flow can get · a year
MarketCuba todayCuba at the Dominican Republic’s rate per person
Remittances received$1.1–2B
2024 est., estimates vary
$9.8B
DR total $11.9B (2025)

A scenario, not a forecast. The Dominican Republic received $11.9B in remittances in 2025 across 11.4 million people, about $1,040 a person; at that rate Cuba’s 9.43 million people would receive about $9.8B a year, five to nine times today. Method and sources.

Expert view · Ric Herrero, Cuba Study Group (Council on Foreign Relations)

Not one U.S. bank onboarded a Cuban entrepreneur under the 2024 rule, because OFAC never set a due-diligence standard. Legal authorization has little value if intermediaries won’t act on it. On cubanew.com ↗

Sources

  1. eCFR, 31 CFR part 1022, rules for money services businesses ↗
  2. FinCEN, MSB registrant search ↗
  3. QvaPay, AML/BSA program and transparency page ↗
  4. Periódico Cubano, Cuba’s private sector imported nearly $1.2 billion in the first half of 2025 ↗
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