Nearly five years after the publication of Resolution 215/2021 by the Central Bank of Cuba (Banco Central de Cuba, “BCC”), the country’s highest banking authority has, for the first time, authorised the use of virtual assets (“VAs”) in cross-border commercial transactions. This authorisation is granted through Resolution 4/2026, published on 23 March 2026, which lists a total of ten companies—nine private MSMEs and one joint venture with foreign participation—that will be allowed, upon entry into force of the regulation, to use virtual assets to settle monetary obligations directly linked to international trade operations within their corporate purpose.
Tracing the regulatory development in this area, Resolution 215/2021 recognised the existence of virtual asset operations outside the Cuban banking and financial system, as well as their risks for monetary policy and financial stability. For this reason, it established the framework for the use of VAs in commercial transactions and for the licensing of virtual asset service providers (“VASPs”) in operations related to financial, foreign exchange, and payment activities in and from Cuban territory. In essence, this framework reserves to the BCC the power to authorise, on a case-by-case basis, the use of VAs and the issuance of VASP licences.
This was followed by Resolution 89/2022 of the BCC, which set out the specific requirements for the authorisation, financing, regulation, supervision, monitoring, correction, and possible revocation of VASP licences operating in or from Cuban territory.
As the first practical experience in granting VASP licences, there is the authorisation granted to the Lithuanian company EBIORO UAB, initially through Resolution No. 8/2025 and subsequently expanded by Resolution 134/2025. This fintech is authorised to:
- Collect, pay, and carry out foreign exchange operations to and from national territory;
- Exchange virtual assets and legal tender currencies, including fiat and digital currencies;
- Safeguard or manage virtual assets and instruments enabling their control, including wallets and digital accounts operated on VASP platforms;
- Execute transfers of virtual assets between users, platforms, and authorised third parties;
- Provide financial services related to the issuance, sale, or intermediation of virtual assets; and
- Develop, manage, and operate the digital platforms, interfaces, and technological systems necessary for all authorised activities under the licence.
As conditions for operation—and reflecting an improved regulatory technique compared to previous resolutions—the new licence (Res. 134/2025) requires the VASP to:
- Clearly and accessibly disclose on its website and service channels the risks inherent in VAs, including high volatility, transaction irreversibility, cybersecurity and fraud risks, and the absence of BCC backing;
- Maintain cybersecurity systems aligned with international standards to protect custodyed assets and platform integrity, subject to periodic technical audits;
- Establish and submit for prior approval by the BCC daily and monthly transaction limits for VA operations, as well as protocols for transfers to bank accounts;
- Maintain clear accounting, operational, and asset segregation between licensed activities and any other services provided outside the Cuban regulatory framework, and submit quarterly external audits certifying such segregation;
- Be subject to on-site and remote supervision by the BCC and the General Directorate for Financial Operations Investigation (responsible for implementing AML/CFT policies), with immediate access to systems, records, databases, and any information required for oversight.
Returning to Resolution 4/2026, the ten companies authorised for one year to conduct VA purchase, sale, transfer, and custody operations may only execute such activities through BCC-licensed VASPs such as EBIORO UAB, and are expressly prohibited from carrying out transactions outside authorised platforms.
Likewise, the beneficiary companies must use virtual assets exclusively to make payments in cross-border commercial transactions (any other use requires new authorisation), and only with the VAs that the contracted VASP is authorised to handle. This may raise practical challenges, as Resolution 134/2025 does not specify which VAs EBIORO UAB is authorised to operate with, suggesting that such details may be contained in non-public, specific authorisations. The ten companies must also report quarterly to the BCC on operations conducted under this authorisation, detailing amounts, VAs used, and the VASP through which transactions were executed.
Although progress has been gradual, the legal framework for crypto-assets in Cuba is increasingly taking shape and being implemented. In a country whose banking and financial system faces significant constraints in accessing traditional financial channels, virtual assets appear to be gaining relevance as viable alternatives. It will therefore be important to monitor the practical effects of these measures, future regulatory developments, and the potential issuance of new licences for VASPs and for the use of virtual assets in cross-border commercial transactions.