Compliance and Defiance on the Fintech Frontier
Todito Cash, Uphold, Airtm, and QvaPay each did two things at once: obeyed local law to the letter and defied assumptions everyone took for granted.
Tim Parsa · Co-Founder & CCO, QvaPay · 14 September 2026 · 4 min read Subscribe
Every fintech I’ve built sat on a frontier, and every frontier asked for the same two things. Compliance, so a bank, a regulator, and a customer could trust it. Defiance of whatever everyone else assumed couldn’t be done. Lose either and you don’t get across.
| Company | Compliance | Defiance |
|---|---|---|
| Todito Cash, 2000 | Built under Mexican law, for Mexican consumers, in pesos. | Of the idea that paying online required a credit card and the legacy card rails most Mexicans didn’t have. |
| Uphold, 2013 | FinCEN registration, state-by-state money transmitter licenses, banks made comfortable, and a compliance program built into the product. | Of the idea that value can only move through trusted intermediaries. Bitcoin had just proved that wrong. |
| Airtm, 2015 | A U.S. company under U.S. law, chosen in 2020 to pay Venezuelan health workers under an OFAC license. | Of a regime that blocked it. Its peer network became an unstoppable first and last mile under harsh currency controls. |
| QvaPay | A FinCEN-registered U.S. company, OFAC screening on every party, a written program, and a Board with an independent director. | Of a regime that wants to own the price of money. Erich built it in Havana the way Airtm was built in Caracas: by people, peer to peer. |
Why both
- Compliance without defiance builds a bank that serves the people banks already serve.
- Defiance without compliance builds something a regulator shuts and a bank won’t touch.
- Both together build the bridge: a product the regime can’t switch off and a U.S. bank can stand behind.
Cuba is the hardest frontier yet
Erich defied the Cuban regime the way Airtm defied Maduro: a dollar account and a peer market that run on people, not on an office the state can raid. QvaPay, Inc. adds the other half: U.S. registration, sanctions screening, a compliance officer on every case, and its open questions put to OFAC in writing, not guessed at.
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.
At Todito Cash I learned the rules before I broke the assumptions. At Uphold I learned how to make a bank comfortable with something new. At Airtm I learned that a peer network survives what a company can’t. QvaPay is all three at once, and the most techno-optimist thing I’ve built.
Obey the law that works: U.S. law. Defy the assumptions. That is how technology crosses a frontier.
Remittances obey U.S. law; the peer market defies the state’s monopoly on money.
| Flow | How we grow it | U.S. tech meets Cuban talent |
|---|---|---|
| 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. |
| 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. |
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.
| Market | Cuba today | Cuba 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.
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
- Tim Parsa, "I Build Money Bridges", 16 March 2020 ↗
- Tim Parsa, "Scaling Stranger-to-Stranger Services", 27 November 2020 ↗
- Uphold ↗
- Airtm ↗
- eCFR, 31 CFR part 1022, rules for money services businesses ↗
- FinCEN, MSB registrant search ↗
- CNN, Venezuelan health workers get cash bonuses via Airtm, 9 September 2020 ↗
- Miami Herald, Venezuelans bypass Maduro's blockade using Airtm, 4 September 2020 ↗
- QvaPay, AML/BSA program and transparency page ↗
If this was useful, pass it to someone building in Cuba.