Cuba has a framework for using virtual assets in payments and for licensing their providers, but it has no securities market, no securities regulator and no issuance regime. Add US sanctions and the conclusion is plain: today it is not viable to tokenize Cuban assets or offer tokens to residents in a structure with international investors.
What the Central Bank of Cuba regulates
- Resolution 215/2021: use of virtual assets in commercial transactions and licensing of virtual asset service providers.
- Resolution 89/2022: authorisation, operation and supervision requirements for those providers.
- Resolution 76/2023: registration and anti-money-laundering rules for providers.
- Resolution 8/2025: the first provider licence, granted to a Lithuanian company; now listed as repealed.
- Resolution 4/2026: authorises ten companies — nine small private firms and one joint venture — to use virtual assets only for cross-border payments, through licensed providers.
It is a payments, exchange and custody framework; there is no securities tokenization regime.
No securities market
The Havana Stock Exchange closed in 1961. The State issues peso sovereign bonds that only circulate between banks and state companies, and the «exchange» projects announced in 2026 have no authorisation as a market. We have found no trust figure usable for an issuance; foreign investment enters through Law 118/2014 as a joint venture, an association contract or a wholly foreign-owned company.
US sanctions
The embargo under the Cuban Assets Control Regulations reaches any person, bank, platform or provider with a US nexus, which includes most dollar stablecoin issuers, custodians and exchanges. The amendment in force since 30 September 2026 extends the ban to indirect transactions with entities on the restricted list, and Cuba was returned to the list of State Sponsors of Terrorism in 2025.
Our position
We treat Cuba as an unsuitable jurisdiction: no Cuban underlying and no resident investors, unless specialists carry out a specific sanctions analysis. If you are looking to structure for the Caribbean or for the diaspora, the Latin America map compares the jurisdictions with a clear regime.
Framework as of 2 October 2026, checked against official sources; regimes change — confirm the current status before structuring.