Fintech & payments regulation in Cuba (2026)

The Banco Central de Cuba issued Resolution 4/2026, granting one-year licenses to nine MSMEs and one joint venture (in IT, gastronomy, transport, and manufacturing) to use cryptocurrency exclusively for cross-border payments, bypassing U.S. sanctions-related banking restrictions. Licensees must file quarterly reports on amounts, crypto types, and intermediaries used.

Cuba's National Assembly approved 176 sweeping economic reforms — the most profound since the Revolution — including authorization of private banks operating under BCC oversight, removal of bank transfer and withdrawal limits, regulation of virtual assets and fintech under 'Axis 11,' and establishment of a real-time digital currency exchange market.

Cuba's banking system descended into acute crisis — long queues at banks and empty ATMs became ubiquitous nationwide — driven by hyperinflation, a CUP 1,000 maximum banknote denomination (worth ~$3 on the parallel market), and cash hoarding by SMEs unwilling to redeposit. The crisis directly exposed the failure of the 2023 mandatory-digitalization policy.

Published in Extraordinary Official Gazette No. 55, Resolution 111/2023 required all state and private companies to accept electronic transfers and capped cash transactions at CUP 5,000 per operation, with fines up to CUP 60,000 and potential business closure for non-compliance. By official admission, only 3.77% of transactions became digital — widely declared a policy failure.

The Banco Central de Cuba published Decree 89/2022 in Official Gazette No. 43, establishing a formal virtual asset service provider (VASP) licensing regime. Any Cuban or foreign individual or entity operating crypto exchanges, custody, or payment services required a one-year renewable BCC license with mandatory AML/KYC: customer ID, transaction monitoring, and sanctions-watchlist screening.

Cuba's Banco Central de Cuba issued Resolution 215/2021 — published in the Official Gazette and effective September 2021 — formally recognizing virtual assets including Bitcoin as a legal medium of payment and investment 'for reasons of socioeconomic interest.' The BCC was designated the sole licensing and supervisory authority for all crypto-related commercial activity, the first explicit crypto legal framework in Cuba.

Cuba launched 'Tarea Ordenamiento' on January 1, 2021, eliminating the Cuban Convertible Peso (CUC) after nearly 30 years and unifying the financial system under a single Cuban Peso (CUP). While intended to simplify digital payment infrastructure, the reform triggered severe inflation; a parallel MLC card circuit persisted to capture hard-currency remittances.

Cuba opened at least 77 state-run retail stores accepting only card payments denominated in Moneda Libremente Convertible (MLC) — a virtual dollar-equivalent currency linked to special BCC-issued MLC debit cards. This created Cuba's first large-scale mandatory card-payment environment and drove mass adoption of bank-card infrastructure across the population.

Cuba enacted Decrees 359 and 360 — the first normative instruments at Council of Ministers level governing the digital economy. Decree 359 established the concept of a software industry; Decree 360 regulated secure ICT use and cyberspace defense. Together they provided the legal scaffolding for subsequent fintech and e-payment regulation.

Cuba's state Defense Information Technology Company (XETID) launched EnZona, a mobile wallet functioning as a domestic PayPal/Venmo equivalent. EnZona grew to over one million users and enabled peer-to-peer transfers and merchant payments within both the CUP and MLC ecosystems, complementing Transfermóvil's utility-payment focus.

ETECSA, in partnership with state banks BANDEC, BPA, and BANMET, launched Transfermóvil on February 10, 2015 — Cuba's first mobile banking app. It enabled utility bill payments, mobile top-ups, and bank transfers via linked debit cards, eventually reaching 5 million registered users and over 110 million transactions per month, becoming the backbone of Cuba's domestic digital payment system.