NewQvaPay Sentinel — sanctions & Cuban-regime screening beyond OFAC: names, entities & crypto addresses.
New Cuba
COMPLIANCENot legal, tax, or investment advice — and not authorization for any transaction. U.S. sanctions (the Cuban Assets Control Regulations, 31 CFR Part 515) heavily restrict — and in most cases prohibit — dealings between U.S. persons and Cuba, including any form of investment or equity in a Cuban business. The rules are complex, fact-specific, and change; nothing on this site is a determination that any transaction is lawful. Structure anything Cuba-facing only with qualified OFAC sanctions counsel, and screen every party (names, entities, wallets) with QvaPay Sentinel.Primary sources: OFAC Cuba Sanctions · 31 CFR Part 515 (CACR) · OFAC Cuba FAQs · Cuba Restricted List
Layer 1 · Narrow lane today

Support Cuba's independent entrepreneurs

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 listed private-sector goods/services; recipients must be genuinely independent, screened, and never prohibited government officials or Party members (§515.337 / §515.338). Nothing on this page authorizes a specific transfer.

QvaPay is the product rail we point to: a U.S. fintech built to screen senders, recipients, and wallets against OFAC SDN and Cuba Restricted List data and to keep settlement off GAESA, FINCIMEX, and Cuban state banks — so dollars 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

  1. 1. Send money. Remittances and payments to an independent Cuban entrepreneur — a freelancer, a cuentapropista, a small farmer, or a MIPYME.
  2. 2. Help them bank in dollars. U.S. banks can open and run a dollar account for them — even remotely — and “U-turn” transfers can clear through the U.S. system.
  3. 3. Buy from them. Pay to import the goods and services independent entrepreneurs produce.
  4. 4. Get them online. Pay for internet, telecom and web services.
  5. 5. Give. Donate to vetted Cuban nonprofits (see Nonprofits).

The one rule under all five: it goes to the independent private sector, through a screened, sanctions-aware rail — never the state, the military (GAESA), FINCIMEX or state banks — and you structure it with OFAC counsel.

You (U.S.)QvaPay — screens sender · recipient · walletIndependent Cuban entrepreneur✕ never the state / GAESA / FINCIMEX
1

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.

2

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 (2025) narrowed who qualifies — treat eligibility as fact-specific and changing.

3

QvaPay as the rail

QvaPay is a sanctions-aware payments platform (U.S. Delaware C-corp) that screens senders, recipients, and wallet/crypto addresses and is designed to avoid Cuban state banks, FINCIMEX, GAESA, and Restricted-List counterparties. Screening ≠ OFAC blessing of every transaction.

Banking, not just payments

Bank the private sector — dollar accounts for Cuban entrepreneurs

Since May 2024 the CACR opens banking, not only remittances. U.S. depository institutions may open and maintain bank accounts solely for independent Cuban private-sector entrepreneurs — a cuentapropista, a freelancer, or a MIPYME — including remotely (§515.584(h)), so they can hold and use a U.S.-dollar account. And “U-turn” transfers (§515.584(d), reauthorized in 2024) let authorized funds transit the U.S. financial system. Together they give Cuba's private sector real access to the dollar-banking rails — the lane QvaPay is built for. Structure any account or transfer with qualified OFAC counsel; nothing here authorizes a specific one.

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.

Cuban startup & remittance communities

Independent communities on Slyk (QvaPay's platform). These are community / collaboration spaces — not equity offerings, not securities advice, and not a determination that joining or transferring value is OFAC-authorized. Do your own diligence.

Cuba Startup Community

$QVA

A Slyk-powered community of independent Cuban tech founders and startups, connected with global mentors and collaborators. Join to collaborate — community coin mechanics are not equity and are not an OFAC authorization.

Independent Remittance Community

$XFX

A Slyk-powered community of independent fintech builders focused on peer-to-peer remittance tooling. Informational / community space — not a license determination and not an equity offering.

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.

Legal authorities (read carefully)

Eligibility definition plus the general licenses that can open a private-sector lane — each with its own scope. None of these is a blanket authorization for every payment.

515.570
Remittances — including, under §515.570(g)(3), remittances to support the development of private businesses in Cuba and operation of non-state economic activity by independent private sector entrepreneurs (§515.340). Family and other donative remittances are also covered, with recipient and source limits.
The core remittance lane for U.S. persons who want to support independent private-sector activity. It is remittance/support-shaped — not a general commercial 'pay any Cuban business' authority, and not equity. Facts, screening, and counsel still decide whether a given transfer fits.
515.340
Not a license — a definition. Defines 'independent private sector entrepreneur' (excludes prohibited Cuban government officials and Communist Party members; caps qualifying private businesses/cooperatives at 100 employees).
Eligibility gate for the private-sector GLs. A MIPYME or its owners must fit this definition; GAESA / Restricted-List / state-controlled counterparties do not.
515.582
Import into the U.S. of certain goods and services produced by independent Cuban entrepreneurs (per the State Department's Section 515.582 List), including payments necessary to those imports, with documentary proof of independent status.
Import-tied only — not a free-standing outbound 'support payments' license. Relevant when a U.S. person is buying listed private-sector goods/services; does not by itself authorize every remittance or commercial payment.
515.542
Mail and telecommunications-related transactions and payments involving Cuba — data, telephone, internet connectivity, and related contracts — excluding prohibited officials/Party members.
Telecom and connectivity lane. Does not authorize payment platforms or wallet rails as such; it covers mail/telecom services and payments incident to them.
515.578
Export/reexport to Cuba of certain internet-based communication and supporting services (messaging, hosting, software design, IT/cloud services, e-learning, etc.) and importation of Cuban-origin software.
Internet-services and software lane for digital activity with Cuba. Supports certain IT/cloud/software dealings; it is not a general license to invest in or buy equity in a Cuban fintech.
515.584(h)
U.S. banking institutions may open and maintain accounts solely in the name of a Cuban national who is an independent private sector entrepreneur (§515.340), for conducting transactions authorized or exempt under the CACR.
Bank-account authorization for qualifying independent entrepreneurs — cite this when discussing U.S. accounts, not as a general investment lane.