New sanctions · Sept 30, 2026What changed, and how QvaPay keeps the lawful lanes open →
Permitted Fund FlowsSee the flows →
QvaPay SentinelTry Sentinel →
New on The WorldListen →
New Cuba
⚠ 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 · the AI stack

Building Fintech in the Age of AI

Bouncer, Sentinel, Crypto Teller, and SkyMind: how two co-founders run a U.S.-to-Cuba payments company on their own AI.

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

Share
Building Fintech in the Age of AI

When I built the compliance programs at Uphold and Airtm, every function was a vendor: one for identity, one for screening, one for monitoring, one for crypto, and a room of analysts reconciling what each saw. With AI, QvaPay builds its own.

Four tools, one ledger

ToolWhat it doesWho decides
SentinelScreens every party and address against the SDN List, the Cuba Restricted List, prohibited officials and Party members, and the UN, EU, and UK lists, at onboarding, on every payment, and after every list update. Public demo at sdn.qvapay.com.A possible match is held for our compliance officer; a confirmed one is blocked and reported to OFAC.
BouncerSweeps the whole ledger every day for structuring, velocity, funnels, pass-through, and counterparty spread, and checks each account against its declared purpose.Restricts on a fail and writes the case; the compliance officer reviews and decides on any report.
Crypto TellerOur in-house crypto processor: a fresh address and the on-chain hash on every deposit, and no withdrawal broadcast until Sentinel clears the destination.USDC only, from and to screened wallets.
SkyMindIn final development: completes assisted purchases by card, assisted vendor payments by bank, and assisted withdrawals on the peer market.Vendor payments are released by the compliance officer against documents.

Why build instead of buy

  • One record. Every check writes to the same ledger, so an examiner sees one story, not four vendors’ exports.
  • Cuba-specific. No vendor ships Cuban name variants, Party-member definitions, or the 30 September 2026 rules out of the box. We tune for them every week.
  • Cost. A compliance program priced for a bank doesn’t fit a market where the average remittance is a few hundred dollars.
What arrives from the United States
The strongest currencyEvery flow runs on QUSD, backed one to one by USDC.
Delivered on blockchain railsChecks run in seconds, on every transaction.
Built-in complianceAI does the sweeping; a compliance officer decides.
A P2P forex marketSkyMind keeps the peer market fair and on the record.
Backstory · From vendors to code

At Airtm we spent a fortune stitching vendors together. Erich builds the way Cubans have always built: with what’s at hand, and better. In the age of AI, what’s at hand is enough to build the whole stack.

U.S. technology, built by Cuban talent, running a U.S.-registered, sanctions-screened company. That’s Techno-Cubanism in one stack.

Fund flows in this post

SkyMind completes the assisted flows and Crypto Teller settles crypto; AI makes each one fast and screened.

FlowHow we grow itU.S. tech meets Cuban talent
Assisted purchases
U.S. payer: §515.533 with SCP · from a Cuban balance: pending with OFAC
SkyMind completes card purchases on the customer’s behalf; more U.S. merchants, more categories.Cuban buyers get U.S. goods and software without a card of their own.
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.
Assisted withdrawals
Pending with OFAC · peer pays from own funds
SkyMind routes each withdrawal to a screened peer who pays from their own funds.Dollars become pesos in hand from a peer's own funds; QvaPay never pays into a Cuban bank.
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. QvaPay Sentinel, public screening demo ↗
  2. QvaPay, AML/BSA program and transparency page ↗
  3. eCFR, 31 CFR part 1022, rules for money services businesses ↗
  4. FinCEN, MSB registrant search ↗
  5. OFAC, Sanctions List Search ↗
  6. U.S. Department of State, Cuba Restricted List ↗
  7. eCFR, 31 CFR § 515.337 ↗
  8. eCFR, 31 CFR § 515.338 ↗
  9. Periódico Cubano, Cuba’s private sector imported nearly $1.2 billion in the first half of 2025 ↗
Share this episode

If this was useful, pass it to someone building in Cuba.

Get every Techno-Cubanism post by email. Free, one email per post, open to everyone. Unsubscribe any time.