Support Cuba's independent private sector
The clearly framed CACR path for U.S. persons is support, and the eligible class is individual-first. §515.340's “independent private sector entrepreneur” covers both individual founders — self-employed cuentapropistas, independent contractors and consultants (a freelance developer or designer, i.e. a digital entrepreneur), small farmers and sole proprietors — and small private businesses (MIPYMEs). §515.570(g)(3) frames OFAC-authorized remittances to support them. §515.582 covers payments to import goods except the categories the State Department's §515.582 List excludes, and services, which carry no listed exclusions — with proof of independent status. Nothing on this page authorizes a specific transfer.
QvaPay is the product rail we point to: a U.S. FinCEN-registered fintech built to screen senders, recipients, and wallets against OFAC SDN and Cuba Restricted List data. Rather than connecting to Cuban state banking rails or regime-licensed payment processors, its peer-to-peer (P2P) forex marketplace of independent Cuban traders completes the CUP/MLC ↔ QUSD conversion leg — so value can reach Cuba's independent private sector when the facts fit a license. Structure every Cuba-facing transfer with qualified OFAC counsel.
How U.S. persons can help — in plain language
Each permitted flow, with the CACR general license that authorizes it:
- 1. Send money. Remittances and payments to an independent Cuban entrepreneur — a freelancer, a cuentapropista, a small farmer, or a MIPYME (§515.570(g)(3); family remittances under (a), donative under (b)).
- 2. Sell to them. U.S. exports to the independent private sector for its own economic activity, and the payment for them (§515.533 + BIS License Exception SCP §740.21(b)(1), subject to BIS's 4 March 2026 suspension condition; paid from a Cuban business account to the U.S. seller only).
- 3. Buy from them. Pay to import goods except the categories the State Department's §515.582 List excludes, and services, which carry no listed exclusions — with proof of independent status (§515.582; proof per the State Department's §515.582 List).
- 4. Get them online. Pay for internet and web services (§515.578) and telecom (§515.542).
- 5. Give. Donate to Cuba — donative remittances (§515.570(b)) — via vetted nonprofits (see Nonprofits).
The one rule under all five: it goes to the independent private sector, over the screened P2P rail described below (cash moves between peers; QvaPay never touches it), structured with OFAC counsel.
One plain-language guide per permitted flow — the authority, the steps in QvaPay, the documents.
Every U.S.–Cuba fund flow, with its authority and standing: allowed or prohibited.
How a peer-to-peer conversion leg differs from legacy remittance rails — with the rates, dated.
Send via QvaPay, pay for a permitted purpose, or onboard your Cuban business.
The eligibility definition and every general license, each with its own scope.
What September 30 broke — and how QvaPay keeps the lawful lanes open
The rule closed the offshore routes and the bank accounts of Cuban entrepreneurs. It left open the payments U.S. law authorizes — and those are the ones QvaPay is built to run: screened end to end, with no Cuban state party and no third-country bank.
U.S. banks may no longer hold accounts for Cuban entrepreneurs, and existing ones must be blocked (§515.584(h)(2) withdrawn; OFAC FAQ 1273).
QvaPay is a payment service, not a bank. It processes the payments U.S. law authorizes — remittances in, contractor and export payments — as transactions ordinarily incident to them (§515.421; OFAC FAQ 756).
Processing authorized payments: allowed. Business accounts and their balances: incident to authorized payments, in QvaPay's reading of §515.421 and OFAC FAQ 756.
Every fund flow →The U-turn is gone: a dollar wire that starts and ends outside the U.S. with a Cuban interest is rejected. The Panama and Hong Kong import route — and its 12% toll — is illegal under U.S. rules for anyone who touches it from the United States: the wire is rejected at the correspondent bank when Cuba is in the file, and hiding it is evasion (§515.584(d); FAQ 1272). Swapping Colón for Veracruz, Caucedo, Mexico or a direct sailing changes nothing.
The Cuban buyer pays a U.S. seller from its QvaPay business account: QvaPay wires dollars from its U.S. bank to the seller's U.S. account against the FOB/FCA Port Everglades invoice in the buyer's name, the export authorization and the EEI. No third-country bank, no cash processor in Havana.
The export: allowed (§515.533). The payment from the Cuban business account to the U.S. seller: allowed as incident to that export (§515.533(a); §515.421). The U.S. side ends at FOB/FCA Port Everglades.
The Florida route →A Cuban business may no longer pay a supplier outside the United States for foreign goods or services through U.S. rails.
QvaPay points Cuban buyers to U.S. sellers that own the goods in the U.S. before the order — U.S. manufacturers, U.S. distributors, or QvaPort (launching in November), which buys its stock in advance with its own money, U.S.-made or held in the Florida foreign-trade zone.
Sales from U.S. sellers that own the goods in the U.S.: allowed (§515.533). Payment to a supplier outside the U.S.: never.
Why, and what works instead →Indirect dealings with Cuba Restricted List entities are now prohibited, and structuring around them is itself a violation (§515.209; §515.201(c)). One GAESA-linked processor or importer anywhere in the chain taints the payment.
Sentinel screens every party and every leg — sender, recipient, owners, exporter, carrier — against the SDN List, EO 14404 designations and the Restricted List. No state bank, FINCIMEX or state importer is ever payer or payee.
A control QvaPay applies to every payment.
QvaPay Sentinel →Remittances were not cut — but every leg is now screened for Restricted List entities, which rules out the state remittance companies and state banks.
Dollars from the United States arrive in seconds. The family converts with a verified peer at the market rate, never at the official rate and never through a state channel.
Allowed (§515.570), forwarded under §515.572(a)(3); pesos change hands between independent peers.
Send a remittance →With entrepreneur accounts frozen, paying a Cuban freelancer through a bank got slower and riskier.
U.S. companies pay independent Cuban contractors in dollars, each on their own invoice, through QvaPay.
Allowed for U.S. payers (§515.582; §515.340(b)). Not employment.
Pay a contractor →QvaPay, Inc. is a FinCEN-registered money services business, not a bank. Not legal advice.
The permitted flows
Each permitted U.S.–Cuba fund flow, with its general license, its controls, and a person-by-person illustration.
Every flow, with its authority and its standing
Each flow rests on an express authorization in 31 CFR Part 515 (or BIS 15 CFR 740.21), with what the sender and recipient must satisfy and a link to the primary source. The platform's own role is the same on every flow: processing a payment that is ordinarily incident to the authorized transaction (§515.421 — OFAC FAQ 756 confirms online payment platforms may facilitate or process authorized transactions), not holding bank accounts for Cuban businesses. OFAC treats registered money transmitters as banking institutions (FAQ 1090), so a balance held for a person in Cuba is limited to receiving authorized U.S. payments and remitting them (§515.584(h); FAQ 748); business accounts and balances are, in QvaPay's reading, incident to the authorized payments that fund them (§515.421; FAQ 756), a Cuban business account pays only U.S. sellers (§515.533), and cash moves between peers without QvaPay touching it. No U.S.-origin funds are settled to the state, GAESA or state banks — every party is screened first; where a household applies a remittance to its own utility bill, that payment is made inside Cuba from pesos already held there.
What a Cuban private business can and cannot do with QvaPay →
Send Money & Essential Services
Send value to a family or an entrepreneur, or donate — recipients hold QUSD or sell it to a peer for pesos, and spend as they choose — rent, food, utilities, medicine. Balances: QvaPay's reading of §515.421 and OFAC FAQ 756 — a payment service incident to the authorized remittance. Cash moves P2P between peers, and QvaPay never touches it.
Remittance / support
Fee: 0.2–2% funding by crypto, by coin; 5.5% by card; 1% on crypto withdrawals, 2% to a U.S. bank.
- Sender
- A U.S. person — 18 or older for family and donative remittances (§515.570(a), (b)(4)) — identity-verified and screened against the SDN List and the Cuba Restricted List; self-certifying, not a determination.
- Recipient
- A close relative, a Cuban national, or a genuinely independent private-sector entrepreneur (§515.340) — never a prohibited Government of Cuba official or prohibited Party member.
On the example rail, P2P forex traders are identity-verified, screened, and certify Cuba residence. QvaPay never touches the cash: peers settle it between themselves, under full controls.
See how QvaPay does itP2P leg terminates in Cuba
- QvaPay has no account or settlement relationship with any Cuban bank — the dollars stay in the U.S.-held balance until an independent Cuban peer buys them.
- No FINCIMEX or other state remittance processor anywhere in the chain.
- QvaPay never holds or moves pesos; the peso side is the trader's own money, already in Cuba.
The CUP/MLC side of a peer trade is settled between the two peers outside QvaPay — in cash or through the peer's own Cuban bank account. QvaPay does not hold, move, see or certify that leg; it records only the QUSD side. Peers trade their own funds, declare their activity, are limited in volume against it and are reviewed when they exceed it; a peer located in the United States may not trade on the market. Crypto funding is accepted only in USDC from screened wallet addresses; inflows from unhosted wallets receive source-of-funds review, and the same $3,000 recordkeeping applies.
Screened: Sender and recipient screened at funding and at transfer; the peer is a verified account holder — screened, with volume limits against declared activity; §515.337/338 attestation on the recipient.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
A Union City prayer group — fourteen donorscomposite illustration
Fourteen members of a parish prayer group in Union City each send their own donative remittance from their own verified QvaPay account — $300 each, $4,200 in total, to fourteen screened beneficiary households. Each donor records her own purpose attestation on her own funding: donative remittance for food and medicine, no household connected to the Government of Cuba. Each donor funds and sends her own remittance from her own account; the parish does not collect, hold or forward funds and is not a remittance forwarder.
Every donor is identity-verified and 18 or older, as §515.570(b)(4) requires. Each named beneficiary is screened against the SDN list and the Cuba Restricted List, and against the prohibited-official and Party-member definitions at §515.337 and §515.338. Two names came back needing a second identifier; the donors supplied carné numbers and both cleared.
Each household sells its own QUSD balance to a peer of its choosing. Ofelia Guerra sells hers to Yaneisy Cabrera, who pays her in CUP from her own money at the rate she quoted that morning. Yaneisy is a verified account holder — screened, with volume limits against her declared activity and enhanced review above them. What reaches Ofelia is Yaneisy's money; what Yaneisy receives is the QUSD balance Ofelia's donor sent.
No foreign funds entered a Cuban bank, and QvaPay has no account or settlement relationship with any Cuban bank or regime payment processor. The peso side is Yaneisy's own money; it settles between the two of them, outside QvaPay, which records only the QUSD side.
No foreign funds in any Cuban state bank, and no QvaPay relationship with one. No FINCIMEX or other regime payment processor. No state-owned remittance operator. The value moved from each donor's own U.S. account to her own QvaPay balance, to the beneficiary's balance, to an independent Cuban peer, and from that peer's own cash to the beneficiary.
- Identity verification (government ID and selfie) and screening on all fourteen donors and every named beneficiary — for persons in Cuba, verification is documentary and residence is attested
- SDN and Cuba Restricted List screening on both ends
- Prohibited-official and Party-member filter (§515.337, §515.338)
- Donor age verification (§515.570(b)(4))
- Purpose attestation on each donor's own funding
- The peer is a verified account holder: screened, with volume limits against declared activity
Composite illustration based on real QvaPay transaction patterns. Names, amounts and identifying details have been changed. Not a determination that any transaction is authorized.
Not a determination that any transaction is authorized.
Top-Ups & Assisted Purchases
Top up a phone, buy online services, or send goods to someone in Cuba.
Prepaid top-up in Cuba (mobile · Nauta) — peer-terminated
Fee: 0.5% per top-up.
- Sender
- A U.S. person sending value so a particular Cuban's mobile, data or Nauta service stays funded — a §515.570 remittance, screened; the top-up is completed in Cuba by a peer.
- Recipient
- The Cuban user whose line or account is topped up — not a prohibited official or Party member. Direct payment to the carrier for a particular Cuban's service is separately authorized by §515.542(c); the rail does not use it and never settles with ETECSA.
On the example rail, P2P forex traders are identity-verified, screened, and certify Cuba residence. QvaPay never touches the cash: peers settle it between themselves, under full controls.
See how QvaPay does itP2P leg terminates in Cuba
- QvaPay never pays the state telecom operator — no account, no settlement relationship, no funds sent.
- QvaPay has no relationship with any Cuban bank or state payment processor.
- A P2P transaction, not a withdrawal through the fiat door: the QUSD moves to the peer, who buys the service locally with pesos already in Cuba.
The CUP/MLC side of a peer trade is settled between the two peers outside QvaPay — in cash or through the peer's own Cuban bank account. QvaPay does not hold, move, see or certify that leg; it records only the QUSD side. Peers trade their own funds, declare their activity, are limited in volume against it and are reviewed when they exceed it; a peer located in the United States may not trade on the market. Crypto funding is accepted only in USDC from screened wallet addresses; inflows from unhosted wallets receive source-of-funds review, and the same $3,000 recordkeeping applies.
Screened: Sender and user screened; §515.337/338 attestation on the user; internal limits on top-up amounts; the peer is a verified account holder, screened.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
Damaris stays connectedcomposite illustration
Damaris books every client on WhatsApp. When her line goes dead her week stops, so her sister Yolanda keeps it funded: $30 covers the mobile line and two months of Nauta data.
The chain matters more than the amount. Yolanda funds the balance. The balance sits in Damaris's verified account. Damaris requests a top-up withdrawal. Leandro Pupo pays for the line and the Nauta account locally, in pesos, from his own funds. The service activates on Damaris's phone. Leandro receives the dollar balance.
Telecommunications service to particular individuals in Cuba is expressly authorized. §515.542(c) reaches activation, usage and pre-paid fees; §515.578 reaches internet-based services; and where the value simply arrives as support for Damaris, §515.570 applies. The authorization exists even though the provider is state-owned.
QvaPay does not use it. It holds no account with the telecom operator, sends it no funds, and has no settlement relationship with it. A private Cuban peer buys the service with money already in Cuba. Damaris is screened, as is Yolanda, and neither is a prohibited official or Party member — the guardrail this flow turns on.
No Cuban state bank, no regime payment processor, and no payment of any kind from QvaPay to the state telecom operator. QvaPay holds no account with it. The peer bought the service locally with his own pesos.
- Identity verification and screening on sender and recipient
- SDN and Cuba Restricted List screening both ends
- Prohibited-official and Party-member filter
- Purpose attestation
- The peer is a verified account holder, screened
- Internal limits on top-up amounts
Composite illustration based on real QvaPay transaction patterns. Names, amounts and identifying details have been changed. Not a determination that any transaction is authorized.
Not a determination that any transaction is authorized.
Buy From, Sell To & Pay for the Private Sector
Buy what entrepreneurs make, pay independent Cuban contractors and studios, or sell them goods exported from the United States. A PYME's payment to a supplier outside the United States for foreign-made goods is prohibited since September 30, 2026 and is shown here only for the record.
Buy / import their goods & services
Fee: The U.S. buyer’s funding fee (0.2–2% by crypto, by coin; 5.5% by card); the Cuban seller pays 1% on a crypto withdrawal (2% to a U.S. bank), plus 0.25% per P2P trade (0% with Gold).
- Sender
- A U.S. person, screened, paying to import goods or services from an independent Cuban entrepreneur — goods must not fall on the State Department's §515.582 exclusion list; services carry no such exclusions — §515.582 itself authorizes all transactions, including payments, necessary to import them.
- Recipient
- The independent entrepreneur or MIPYME that produced the goods/services — screened, with documentary proof of independent status (§515.340).
On the example rail, P2P forex traders are identity-verified, screened, and certify Cuba residence. QvaPay never touches the cash: peers settle it between themselves, under full controls.
See how QvaPay does itP2P leg terminates in Cuba
- The dollars are never remitted into Cuba — they stay in a U.S.-held balance until an independent Cuban peer buys them.
- QvaPay has no relationship with any Cuban bank or state payment processor.
- Excluded HTS goods (rum, tobacco, minerals, machinery, vehicles) are not processed; services carry no exclusions.
The CUP/MLC side of a peer trade is settled between the two peers outside QvaPay — in cash or through the peer's own Cuban bank account. QvaPay does not hold, move, see or certify that leg; it records only the QUSD side. Peers trade their own funds, declare their activity, are limited in volume against it and are reviewed when they exceed it; a peer located in the United States may not trade on the market. Crypto funding is accepted only in USDC from screened wallet addresses; inflows from unhosted wallets receive source-of-funds review, and the same $3,000 recordkeeping applies.
Screened: KYC/KYB on the MIPYME and every beneficial owner; §515.340 independent-status documentation; buyer and MIPYME screened both ends; trader screened.
Describes the example rail's design; not a determination that any transfer is authorized. The P2P leg, explained →
Priya commissions Taller Almendarescomposite illustration
Priya commissions cover art and interior layout for three books: $2,400 to Taller Almendares, a four-person design studio in Havana.
This is an import — of a service, from Cuba to the United States — and §515.582 authorises all transactions, including payments, necessary to import goods and services produced by independent Cuban entrepreneurs. The studio's services fall outside the §515.582 List entirely — its exclusions are goods-only — and its independent status under §515.340 is documented: license, ownership structure, and both beneficial owners identified and screened. Dayana holds 55 percent, Rubén 45.
Two things the file records deliberately. First, the exclusions to this authority apply to goods only; services carry none. Second, nothing in this engagement touches an excluded Harmonized Tariff Schedule section — no rum, no tobacco, no minerals, no machinery, no vehicles. Those are excluded from import and QvaPay does not process them. (Coffee, once excluded, has been eligible since the State Department's 2016 update.)
Payment lands as a QvaPay balance in the studio's name. When the owners want pesos, Maikel Duarte buys the balance at the market rate and pays them from his own funds. The dollars never enter a Cuban bank. They stay in a U.S.-held balance until an independent Cuban buys them.
No Cuban state bank and no regime payment processor. The dollars were never remitted into Cuba at all — they stayed in a U.S.-held balance and were bought by a private Cuban peer, who paid the studio in pesos he already held.
- KYC/KYB on the studio
- Both beneficial owners identified and screened
- §515.340 independent-status documentation (services carry no §515.582 exclusions)
- SDN and Cuba Restricted List screening both ends
- HTS exclusion screen recorded on the goods question
- Purpose attestation and commercial invoice
- The peer is a verified account holder, screened
Composite illustration based on real QvaPay transaction patterns. Names, amounts and identifying details have been changed. Not a determination that any transaction is authorized.
Not a determination that any transaction is authorized.
The rail processes only the money leg. The U.S. seller, which owns the goods in the United States before the order (its warehouse or a Florida foreign-trade zone), is the exporter and sells FOB/FCA Port Everglades; the Port Everglades → Mariel freight is booked by QvaPort and re-invoiced at cost, or arranged by the Cuban buyer's logistics company when it buys directly, and the buyer pays every Cuban port charge in Cuba, outside QvaPay, at cost, on a separate receipt. Goods that never touch the U.S. (e.g., China → Panama → Cuba) are not paid by the rail.
Guide: selling to Cuba from any country through a Florida foreign-trade zone →
A Cuban private enterprise with a QvaPay enterprise account can pay a U.S. exporter for goods exported from the United States under a Commerce authorization — sold by a U.S. seller that owns the goods in the U.S. before the order: a maker, a distributor or QvaPort (launching in November) (§515.533; §515.421). Payments to any supplier outside the United States are not processed. Payments to suppliers outside the United States for foreign-made goods, and payments for non-U.S. services, are prohibited since September 30, 2026, when OFAC withdrew §515.584(h)(2); the rail does not process them.
Import → sell → earn → import more
market-priced conversion · no state intermediaries · payment only to a U.S. seller
Illustrative only. This is not legal advice and not a determination that any transfer is authorized, and OFAC has not reviewed or approved this material. Eligibility is fact-specific; screen every party with QvaPay Sentinel and structure any transfer with qualified OFAC counsel.
Why the P2P rail
One design choice — the CUP/MLC ↔ QUSD conversion leg, peer-to-peer by design — separates this rail from legacy remittance services.
Why the peer-to-peer conversion leg matters
What makes QvaPay categorically different from Western Union, MoneyGram, and card processors is one design choice: the CUP/MLC ↔ QUSD conversion leg — peer-to-peer by design. Legacy services connect and settle directly with the regime's payment processors and state banks (FINCIMEX, GAESA). QvaPay doesn't — independent Cuban P2P forex traders complete the conversion between themselves. Everything below follows from that:
Cash moves between peers on the P2P market; QvaPay never touches it. The exchange runs under full controls.
- Rails: connect & settle directly with regime processors (FINCIMEX) and state banks.
- Exchange rate: the state's segmented rates — 24 and 120 CUP/USD on its own books, and a rationed CADECA float at 813 CUP/USD (Banco Central de Cuba, 2026-11-11).
- Privacy: sender & recipient identity handed to the regime — surveillance and censorship.
- Who profits: fees and FX spread flow to regime-controlled entities (GAESA).
- Rails: no direct regime connection — independent Cuban P2P forex traders complete the CUP/MLC ↔ QUSD conversion leg.
- Exchange rate: the executed peer rate on QvaPay's P2P exchange — 1085 CUP/USD (QvaPay P2P API, completed pairs average, 2026-11-11). Informal cash rate: see elTOQUE.
- Privacy: sender and recipient identity is not handed to regime processors, as it is on a state-bank-settled transfer.
- Who profits: value stays with the sender, the recipient, and independent traders.
Rates are read at build from their sources and refreshed on publish — QvaPay P2P exchange (completed pairs average, bank CUP): api.qvapay.com ↗ · state segments and the CADECA float: Banco Central de Cuba ↗ · informal cash rate: elTOQUE ↗ · retrieved 2026-11-11.
Every transfer builds the private sector twice. The recipient is an independent entrepreneur — and so is the P2P forex trader who completes the conversion leg and earns the spread. Where a legacy transfer feeds the regime's remittance monopoly, a P2P transfer funds two independent Cubans and thickens a self-expanding, free-market network the regime doesn't run. Scale the volume and you scale the number of independent operators — the opposite of a state-controlled pipeline.
This describes how the rail is designed, screened at every step with QvaPay Sentinel. It is not a guarantee for every third-party path and not an OFAC determination — structure any transfer with qualified counsel.
Financing is what the March 2026 condition kills — and what the carve-out saves
On 4 March 2026 BIS suspended License Exception SCP §740.21(b)(1) for any export, reexport or in-country transfer “involving the deposit of foreign funds into a Cuban owned bank.” It left one door open: transactions that avoid Cuban banks — “third country banks or other financial payment systems.”
Since then, a U.S.-origin fuel shipment to Cuba's private sector keeps its export authorization only if no foreign funds are deposited into a Cuban-owned bank anywhere in the payment chain. Though written about deposits, the condition functionally restricts financing: a purchase from the MIPYME's own revenue never involves foreign funds; only a foreign-financed purchase can trigger the named deposit. Read that against how a foreign-financed import actually moves money:
A financier abroad wires funds to the Cuban buyer's bank so the buyer can pay for the shipment. That wire is the named deposit. Authorization forfeited — before the official-rate conversion even gets to destroy most of the value.
The financier wires to a third-country bank instead — the carve-out names “third country banks” — and the funds then move into a Cuban bank the enterprise can actually use. The second hop is the same named deposit, one step delayed. And the route assumes a Cuban MIPYME can open, fund and operate a foreign bank account at all, which a licensed MIPYME can rarely do; even when it can, deploying those funds inside Cuba draws them into a Cuban bank.
The carve-out's other channel — “other financial payment systems” — is in practice the only way foreign financing reaches an independent Cuban enterprise with the export authorization intact. On a closed digital-dollar rail, the financier's funds never enter Cuba: they are held as QUSD in the United States and leave exactly once, as the documented import payment from a U.S. bank account to the exporter. The CUP/MLC ↔ QUSD conversion leg happens peer-to-peer inside Cuba, from pesos already there. The named condition is never triggered — in either direction. It is the only delivery of financing that never does. On QvaPay this is how import financing works, as a benefit of the approved business account: a verified financier on QvaPay advances the payment to the U.S. seller and the business repays in QUSD through QvaPay over the agreed term (8.75% per transaction on the financed amount, which QvaPay shares with the financier). Today it runs as microfinancing under the Cuba general licence (31 CFR 515.575), with small tickets; larger amounts come with the specific licence QvaPay has requested from OFAC (case CU-2025-1426925-1). Not available for food and agricultural goods (cash in advance is mandatory, 31 CFR 515.533(a)(4)).
Since 3 September 2026 the stakes are higher still: Banco Exterior de Cuba — the state bank specializing in foreign-trade finance — is an OFAC-designated party under E.O. 14404, so a Cuban bank in the payment path is no longer just a licence-exception problem but a potentially blocked counterparty.
BIS acted under EAR §740.2(b), which allows suspending a licence exception without notice — which is why the suspension does not appear in the CFR text of §740.21. Illustrative; not legal advice.
The P2P forex layer — why screened peer settlement helps compliance
In every flow above, the CUP/MLC ↔ QUSD conversion leg — peer-to-peer by design — is completed by a P2P forex trader: an independent Cuban who pays out in CUP from their own funds and receives the QUSD balance in exchange. That design is what keeps value out of state channels:
QvaPay never touches the cash: peers settle it between themselves, under full controls.
- No regime processor — the rail never connects to FINCIMEX or any state payment channel.
- No Cuban bank on the rail — value stays in U.S.-held balances until an independent Cuban buys it.
- Free-market FX — conversion happens at the rate the traders set between themselves, not the official rate.
- Entrepreneurship — every trade is income for an independent Cuban forex trader.
- Local liquidity — payouts are completed from pesos already in Cuba, so no foreign funds need to enter.
On QvaPay — the example rail used throughout these pages — every P2P forex trader verifies their identity, is screened against U.S. sanctions lists, and certifies that they reside in Cuba before their first trade; they never fund from a U.S. bank account, which for a Cuba resident would be treated as blocked (§§515.302, 515.305; §515.505 unblocks only Cubans living outside Cuba).
Marketplace peers and VIP users attest that they reside in Cuba. Other rails may implement equivalent controls; the above describes the example rail, not P2P settlement generally.
Liset's working capital — the peer's own moneycomposite illustration
Liset needs working capital the way any money-changer does: pesos on hand and a dollar float. Both are her own. Her pesos are three years of spreads, kept in cash. Her dollars are a float of about $2,000 in QUSD, built the same way — trade by trade, on her own QvaPay balance.
Each morning she buys QUSD from families receiving remittances and pays them in pesos from her own cash; the $120 Migdalia's daughter sends from Hialeah each month reaches Migdalia as Liset's pesos. In the afternoon she sells QUSD to private businesses that need dollars to pay U.S. sellers, and takes their pesos. Her float turns over every few days. No money comes in from a U.S. bank account, and none goes out to one.
Her QUSD balance is a payment service incident to authorized transactions, in QvaPay's reading of §515.421 and OFAC FAQ 756. The cash never touches QvaPay. SkyMind AI Payments, QvaPay's automated P2P matching engine, pairs her with buyers and sellers, and the pesos change hands between peers. The flow runs under full controls.
What the controls require of Liset: identity verification, SDN and Cuba Restricted List screening, and a recorded attestation that she resides in Cuba and is not a U.S. citizen or permanent resident. Her trading is limited to her declared activity and reviewed when it exceeds it. She cannot fund her balance from a U.S. bank account: a Cuban national who lives in Cuba is a designated national (§§515.302, 515.305), and an account she kept in the United States is treated as blocked — the unblocking in §515.505 applies only to Cuban nationals living outside Cuba. Her pesos settle hand to hand, outside QvaPay; QvaPay records only the QUSD side and never pays into a Cuban bank.
The only movements on QvaPay are QUSD transfers between verified account holders. Her pesos and the buyers' pesos change hands outside QvaPay entirely. No U.S. bank account of hers, no Cuban bank paid by QvaPay, no regime payment processor.
- Cuba-residence and non-U.S.-person attestation (resides in Cuba; not a U.S. citizen or permanent resident) at activation
- Identity verification and screening
- SDN and Cuba Restricted List screening
- No funding from U.S. bank accounts of Cuba residents (§§515.302, 515.305 — treated as blocked; §515.505 unblocks only Cubans living outside Cuba)
- Business-purpose record — working capital for her declared P2P exchange activity
- Volume limits against declared activity; review above them
- Cash settles between peers; QvaPay never touches it
Composite illustration based on real QvaPay transaction patterns. Names, amounts and identifying details have been changed. Not a determination that any transaction is authorized.
This flow raises an interpretive question QvaPay has put to OFAC — presented as a question, not as authorized activity. Read question Q5 →
Act — send, pay, get onboarded
The rail, the mandatory diligence, and the on-ramps — for U.S. senders and for Cuban businesses.
Support via QvaPay
Use QvaPay only for activity that fits an applicable CACR authorization after your own diligence and counsel review — typically remittance/support to a screened independent private entrepreneur, never equity, never the state or military conglomerate.
Remittance / support lane
§515.570(g)(3) authorizes remittances to support private businesses and non-state activity by independent entrepreneurs (§515.340) — not securities, not equity, and not a blanket commercial ACH to anyone in Cuba.
Screening is mandatory
Recipients must be genuinely independent (not §515.337 / §515.338 prohibited persons). Screen every party against OFAC's SDN list and the Cuba Restricted List with QvaPay Sentinel. NSPM-5 (June 2025) directed OFAC to tighten who qualifies, and the September 30, 2026 rule did — treat eligibility as fact-specific and changing.
QvaPay as the rail
QvaPay (a U.S. Delaware C-corp) screens senders, recipients, and wallet addresses. Screening is required diligence — not an OFAC determination that any transfer is authorized.
Payment services in and out — not bank accounts for Cuban businesses
QvaPay provides payment services in and out for permitted fund flows: money in to Cuba's independent private sector — remittances, donations, import-tied and service payments, connectivity — and money out for a permitted purpose, such as paying a U.S. exporter for an authorized export (a Cuban business account pays only a U.S. seller). It does not open or hold bank accounts for Cuban businesses. On September 30, 2026 OFAC withdrew §515.584(h)(2), the May 2024 license that let U.S. banks hold an account solely in an independent entrepreneur's name; banks holding such accounts must block them (OFAC FAQ 1273), and the “U-turn” license at §515.584(d) went with it. The PYME import payment to a non-U.S. supplier, which this page previously grounded on §515.584(h)(2), is now prohibited: outbound payments are limited to goods exported from the United States under a Commerce authorization (§515.533 — sold by a U.S. manufacturer or distributor from the United States) and CACR-licensed U.S. services, and the rail does not process the rest. The platform's own basis is the same on every flow: OFAC's FAQ 756, reaffirmed September 29, 2026, confirms that a person subject to U.S. jurisdiction may use online payment platforms to facilitate or process authorized transactions as transactions ordinarily incident under §515.421 — the underlying general license authorizes the transaction, and the platform's processing is incident to it. Structure any transfer with qualified OFAC counsel; nothing here authorizes a specific one. Source: FR Doc. 2026-19973 (effective Sept. 30, 2026) · OFAC FAQ 1273 · OFAC FAQ 756.
Are you a Cuban private-sector business?
If you run an independent MIPYME or are a cuentapropista and want to explore receiving payments through QvaPay's screening rails, get in touch. Onboarding is individual — we do not publish a directory of businesses to pay, and contact is not an OFAC determination.