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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
Essay · the Parsagram

Compliance and Defiance: The Fintech Parsagram

QvaPay sits where four circles meet: compliance with U.S. law, defiance of a failed monetary regime, fiat dollars, and crypto rails.

Tim Parsa · Co-Founder & CCO, QvaPay · 18 August 2026 · 4 min read Subscribe

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Compliance and Defiance: The Fintech Parsagram

People ask how a U.S.-registered company can also be the most subversive financial tool in Cuba. I drew the answer as four circles and called it the Parsagram.

What a Parsagram is. A Parsagram overlaps two sets of opposing domains: here, fiat against crypto and compliance against defiance. Most people never consider where opposites meet. Compliance with defiance, or fiat with crypto, is already a place few look. Overlap two opposing pairs and the rarity compounds: the diagram reveals what almost no one sees. Here, the center is QvaPay.

Four overlapping circles: Compliance, Fiat, Defiance, and Crypto. Their overlaps are USD, free-market forex, P2P, and stablecoins, with QvaPay at the center.
The Parsagram: compliance, fiat, defiance, and crypto, with QvaPay at the center.

Four circles

  • Compliance. U.S. law: a FinCEN-registered money services business, OFAC screening on every party, a written program, records a U.S. bank and examiner can read.
  • Fiat. The U.S. dollar, the currency Cubans already price their lives in.
  • Defiance. Of the regime’s monopoly on money: its decreed rate, its state banks, its processors. Not of U.S. law.
  • Crypto. Rails that move value in seconds, anywhere, at the cost of a text message.

Four overlaps

  • Compliance + fiat = USD. sanctions-screened U.S.–Cuba fund flows: remittances, payments, exports, each under its own rule.
  • Fiat + defiance = free-market forex. Market-priced money. A peso priced by Cubans, not by decree, is an advantage no state bank can match.
  • Defiance + crypto = P2P. Peer-to-peer dollar services the regime can’t switch off, because they run on people, not one office it can raid.
  • Crypto + compliance = stablecoins. QUSD, backed one to one by USDC: global access to the dollar opportunity engine, with every address screened.

Take away any circle and the model breaks. Without compliance, no U.S. bank stands behind us. Without defiance, we’re one more channel feeding the state’s exchange rate. Without fiat, there’s no dollar. Without crypto, the dollar arrives in days, not seconds.

What arrives from the United States
The strongest currencyThe center of the diagram is a dollar balance on a phone.
Delivered on blockchain railsQUSD on Stacks, screened address by address.
Built-in complianceSentinel, Bouncer, and a compliance officer who decides.
A P2P forex marketThe rate Cubans set, not the one the state posts.

The treatment of the P2P exchange itself is the subject of QvaPay’s interpretive-guidance request pending with OFAC. The exchange runs under full controls and no authorization is asserted.

Backstory · Plan B

In 2020 I wrote that money you earn legally but can’t move or convert freely is a violation of your rights. Uphold and Airtm were my first answers. QvaPay is the sharpest one: built to comply with U.S. law, and a standing act of defiance against a regime that wants to own the price of money.

Compliance is how we earn the right to operate. Defiance is why it matters.

Fund flows in this post

Remittances are compliance, the peer market is defiance, crypto is global reach: all inside U.S. law.

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.
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.
Crypto funding and withdrawals
Own funds, screened addresses · withdrawals by persons in Cuba: pending with OFAC
USDC from and to screened wallets, settled by Crypto Teller.Cubans hold dollars on a phone, the way the rest of the internet does.

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. Tim Parsa, "I Build Money Bridges", 16 March 2020 ↗
  2. QvaPay, AML/BSA program and transparency page ↗
  3. QvaPay Sentinel, public screening demo ↗
  4. FinCEN, MSB registrant search ↗
  5. U.S. Department of State, Cuba Restricted List ↗
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