Compliance
Updated September 30, 2026
Every flow QvaPay operates names here the U.S. authorization it relies on; where that authorization is pending before OFAC, the table says so.
Growth of the rail is growth of Cuba's independent private sector.
Leg 1, funding (bank, card, crypto), creates QUSD. Leg 2, disposition (transfer, P2P, business payment, Cuba top-up, assisted purchase, withdrawal), burns or moves QUSD; the Cuba top-up is a move to a peer, not a burn. Every transaction has an explicit landing point.
Leg 1 · Funding
Creates QUSD
QUSD on the ledger
Between registered, screened users
Leg 2 · Disposition
Moves or burns QUSD
One row per flow QvaPay operates, under its public name.
| Flow | Who | U.S. authorization | Key control | Who it builds up |
|---|---|---|---|---|
| Family remittance | Verified sender → individual in Cuba | 31 CFR § 515.570 | Purpose attestation; Sentinel on both parties | Independent households |
| QUSD transfer between users | Holder → another verified holder, within the ledger | Private activity between Cubans; § 515.421 when it gives effect to an authorized payment; § 515.570 when the origin is a remittance from the U.S. | Sentinel on both; purpose attestation on transfers to Cuba from U.S. accounts | Independent households and businesses |
| Payment to a private business | Buyer → verified MIPYME/TCP | § 515.582; § 515.421 | KYB of the business; MEP registry | The private business |
| Imports from Cuba | U.S. buyer ← MIPYME/TCP (goods and services on the State Department § 515.582 list) | § 515.582 | § 515.340 status documentation; KYB | The exporting private business |
| Payments from companies outside Cuba to Cubans (services, payroll) | U.S. or international company → verified freelancer / employee / MIPYME | § 515.582; § 515.421; § 515.578 for the platform | KYB of the payer; Sentinel; Travel Rule | The worker and the private business |
| Account funding by a U.S. company | U.S. company → verified MIPYME | § 515.582; § 515.421 | KYB; purpose attestation | The private business |
| Donation | Donor → independent individual or organization | § 515.570(b) | Attestation; screening | Independent civil society |
| P2P market CUP/MLC ↔ QUSD | Independent Cubans among themselves, own funds | Sale of QUSD for CUP/MLC: delivery in Cuba of value received under a license (§ 515.570, § 515.582; § 515.584(h); § 515.421). Purchase of QUSD: a step incidental to the authorized transaction the buyer executes afterwards (§ 515.421). Confirmation requested from OFAC (§ 515.340; Case ID CU-2025-1426925-1). | Verified residence; no U.S. accounts; escrow | Independent exchangers: every peer is one more private actor |
| MIPYME deposit via P2P | MIPYME converts CUP/MLC sales → QUSD | As the P2P market (purchase); the QUSD is applied to the business's authorized payments (§ 515.421) | KYB; per-transaction screening | The private business |
| Import payment: goods shipped from the U.S. (of any origin, including goods leaving a U.S. foreign-trade zone, FTZ) | MIPYME / TCP → U.S. exporter, from the Company's U.S. bank account | 31 CFR § 515.533(a) (payment incidental to an export authorized by Commerce); BIS License Exception SCP § 740.21, AGR § 740.18 (food) or a BIS license; § 515.421. Goods located in the U.S., FTZs included, are subject to the EAR whatever their origin (15 CFR § 734.3(a)(1)) | Invoice, EAR99/ECCN classification and license exception declared by the exporter, private end use, ITN of the AES filing (also on withdrawals from an FTZ, 15 CFR § 30.52), transport document showing departure from the U.S.; Sentinel on the exporter; Travel Rule | The private business and its supply chain |
| Import payment: goods not shipped from the U.S.Suspended | MIPYME / TCP → supplier in a third country | Suspended as of September 30, 2026. The authorization it relied on (§ 515.584(h)(2)) was removed by OFAC. Specific license requested from OFAC (Case ID CU-2025-1426925-1) | Blocked; no payment is executed | — |
| Withdrawal to own account | Holder → their own wallet (any account); holder → their own bank account (U.S. and international accounts only); Cuban accounts → card or account in Cuba (CUP/MLC) | § 515.421 (own funds); § 515.584(h) for delivery to Cuba | Own name only; Sentinel on the destination; a Cuban account does not withdraw to banks outside Cuba. A Cuban national permanently resident outside Cuba holds a U.S. or international account, not a Cuban one (31 CFR § 515.505), and withdraws as such. | The holder |
| Self-remittance (own U.S. funds to one's own account) | Holder residing in Cuba with a U.S. bank account opened during a prior residence → their QvaPay account. Inbound only | Question put to OFAC; no authorization is claimed; inbound only, under the Manual's controls | Verified residence and ownership | The holder |
| Card sub-account | U.S. or international holder → their own sub-account | § 515.421 (own funds) | Not offered to Cuban accounts pending OFAC's decision | The holder |
| Prepaid top-up in Cuba (ETECSA · Nauta) | Buyer → P2P peer who purchases the top-up in CUP; the QUSD moves to the peer, it is not burned; the Company pays neither the carrier nor any supplier | § 515.542(c); § 515.578 | Recipient identity; $1,000 per top-up / $3,000-per-30-days limits | The connected person |
| Assisted purchase (payments for digital services outside Cuba: international top-ups, gift cards, eSIM, prepaid VISA · personal goods) | Verified user → the Company pays from its bank a U.S. provider of digital services (§ 515.578) or a U.S. seller of goods shipped from the U.S. (§ 515.533 + SCP § 740.21(b)(2)); prepaid codes consumed outside Cuba. The QUSD is burned. | § 515.578; SCP § 740.21(b)(2) | Use attestation; screened supplier. Suppliers outside the U.S. that deliver in Cuba: not paid since September 30, 2026. | The digital entrepreneur, the family |
| Import financing (submitted to OFAC) | Financier → MIPYME → supplier; repayment in QUSD with a capped return | § 515.533, OFAC guidance pending; license in the alternative. Since September 30, 2026, only for goods shipped from the U.S.; for third-country goods the Company has requested a specific license. | F-1; no equity stake; closed cycle with no Cuban bank | The MIPYME: working capital it lacks |
| Savings | Holder ↔ their own balance | Internal movement | No external leg | The saver |
On September 29, 2026 OFAC published amendments to the Cuban Assets Control Regulations effective September 30. Three of them affect us.
What did not change: everything that flows from the United States into Cuba under the general licenses (remittances, payments to the private sector, exports authorized by Commerce, internet services and top-ups) and everything that flows out to Cuba. A Cuban business can still buy merchandise of any origin from a seller who imports it into the United States and ships it from there, including from a U.S. foreign-trade zone (FTZ), where the goods can wait duty-free until they are exported to Cuba.
Every peer in the P2P market is an independent economic actor earning outside the control of the State.
Every MIPYME pays its supplier in days, at the market exchange rate, without the State seeing or capturing the transaction.
The MIPYME's commercial privacy: the State does not read its business in its payments.
Scaling the rail is scaling the number of Cubans who operate outside the State.