US Business Banking for Cuban Founders: Sanctions, Exceptions, and What Is Realistic

Cuba is subject to comprehensive US sanctions under the Cuban Assets Control Regulations (CACR), administered by OFAC. This is one of the longest-standing US sanctions programs. This guide explains what is prohibited, what narrow exceptions exist, and what honest advice looks like for Cuban entrepreneurs.

The legal framework

The CACR prohibits most transactions between US persons and Cuba, including financial services. This means:

• US banks generally cannot open accounts for Cuban nationals or entities
• Wire transfers between Cuba and the US are prohibited in most cases
• US fintech platforms (Mercury, Wise, Relay, Payoneer, Airwallex) do not serve Cuban founders

What changed in May 2024

OFAC amended the CACR in May 2024 to create a specific carve-out for independent Cuban private sector entrepreneurs. The amendment:

• Authorises US banks to open accounts for qualifying independent Cuban private sector entrepreneurs
• Reinstates certain "U-turn" transactions (USD transactions that pass through US correspondent banks)
• Is intended to support Cuba's private sector without benefiting the Cuban government

In practice, this carve-out is narrow and difficult to use. Most major US banks have not updated their internal policies to accept Cuban clients under this exception. The compliance burden of verifying "independent private sector" status is high, and most banks have chosen not to engage.

What is still prohibited

The CACR carve-out does not apply to:

• Cuban government entities or state-owned enterprises
• Members of the Cuban Communist Party or government officials
• Transactions that benefit the Cuban government
• Most commercial banking relationships outside the specific private-sector exception

What fintech platforms say

Mercury, Wise, Relay, Payoneer, and Airwallex all list Cuba as a prohibited jurisdiction. The May 2024 OFAC amendment has not changed their policies in practice. These platforms have chosen not to implement the private-sector exception due to compliance complexity.

What is realistic

For most Cuban founders currently resident in Cuba, US business banking is not currently accessible through mainstream channels. The legal exception exists on paper; the practical implementation has not followed.

Cuban founders who have relocated — to Spain, Mexico, or other countries — can often access US banking through their new country of residence, provided they have a non-Cuban address and are not on the OFAC SDN list.

Cuban founders with a genuine independent private sector business who want to pursue the May 2024 exception should work with a US attorney specialising in OFAC compliance. This is not a DIY process.

What we recommend

If you are a Cuban founder who has relocated, contact us. We can assess your situation and advise on the right structure. If you are currently resident in Cuba, we cannot currently help you open a US business bank account through standard channels, and we will not take fees for services we cannot deliver.

This guide is for informational purposes only and is not financial, tax, or legal advice. Consult a qualified adviser for your specific situation.