Cuba

Retail_Trading_Status

Allowed-Regulated Unknown

Analysis ID: #315
Version: Archived
Created: 2025-06-26 09:22
Run: 2709ecbf...
History: View all versions
Workflow Stage: Initial Research

Executive Summary

Retail cryptocurrency trading is permitted in Cuba, subject to regulation by the Central Bank of Cuba (BCC). Resolution 215/2021 established guidelines for virtual assets, while Resolution 89/2022 detailed licensing requirements for VASPs. The BCC oversees activities, emphasizing AML/CFT compliance. Due to U.S. sanctions, P2P trading remains prevalent, and the government has issued warnings about cryptocurrency risks.

Detailed Explanation

Retail cryptocurrency trading is legally permitted in Cuba but is subject to a regulatory framework established by the Central Bank of Cuba (BCC). This framework was primarily introduced through Resolution 215/2021, which recognized cryptocurrencies and outlined the process for licensing virtual asset service providers (VASPs). Subsequent regulations have further clarified these initial provisions. Resolution 215/2021, effective from September 2021, allows the use of virtual assets for commercial transactions and investments. It defines virtual assets as the digital representation of value that can be commercialized or transferred digitally and used for payments or investments. It also defines providers of virtual assets as any individual or company engaged in certain cryptocurrency transactions, including the exchange of virtual assets to legal tender, the exchange between different virtual assets, the transfer of virtual assets, custody, or administration of virtual assets, and providing financial services related to the sale of a virtual asset. With crypto legally recognized by the BCC, Bitcoin and other cryptocurrencies can now be used for commercial transactions and investments in Cuba. A resolution published in the Official Gazette said the central bank will set rules on cryptocurrencies and determine how to license providers of related services within the communist state. Actually, the first regulatory effort in the field of cryptoassets dates back to Resolution 215/2021. There, it was explicitly stated that transactions with virtual assets between individuals were not prohibited. This pioneering resolution made it legally possible to use cryptocurrencies as a legal mode of payment and allowed approved virtual asset service providers to conduct business within the country.

In April 2022, the BCC issued Resolution 89/2022, which further detailed the requirements and procedures for obtaining licenses for VASPs. These licenses are granted for an initial one-year period, extendable for a second year, highlighting the experimental and evolving nature of cryptocurrency regulation in the country. The BCC is responsible for evaluating license applications based on legality, socioeconomic interest, and the applicant's probity and experience. Cuba's Central Bank (BCC) has published a decree law that establishes the procedures that those providing virtual assets (cryptocurrencies) must comply with to operate legally in the country... The new law makes clear the basis on which individuals and companies will be able in future to operate cryptocurrency exchanges and custody services. It confirms that the BCC is the only institution able to approve virtual asset service provider licenses to individuals or companies.

The regulations also emphasize the prevention of illicit activities. Licensed VASPs are required to comply with BCC rulings concerning anti-money laundering (AML), combating the financing of terrorism (CFT), and weapons proliferation. The regulation requires all license holders to comply with BCC rulings in relation to the prevention, detection, and combating of money laundering, terrorism financing, weapons proliferation, and other similar concerns. The BCC also has the authority to determine which specific cryptocurrencies or digital assets can be listed and traded by licensed entities in Cuba.

Despite these regulations, the practical landscape has nuances. Due to U.S. sanctions, major international cryptocurrency exchanges often do not officially operate in Cuba. This has led to the continued use of peer-to-peer (P2P) trading, often facilitated through platforms like Telegram and WhatsApp, alongside any locally licensed entities that may emerge. The government, while regulating the space, has also issued warnings about the risks associated with cryptocurrencies, such as volatility and their potential use in fraudulent schemes. The Central Bank of Cuba (BCC) has established basic guidelines for cryptocurrency operations: Recognition of cryptocurrencies as a valid form of payment. Requirements for exchange platforms. KYC/AML compliance expectations. Reporting obligations.

Summary Points

Retail Cryptocurrency Trading Status in Cuba (as of June 26, 2025)

I. Regulatory Status:

Allowed-Regulated: Retail cryptocurrency trading is legally permitted in Cuba but subject to regulation.
Individuals can legally buy, sell, and hold cryptocurrencies.
Virtual assets can be used for commercial transactions and investments.

II. Key Regulatory Bodies:

Central Bank of Cuba (BCC):
- Primary regulatory body overseeing cryptocurrency activities.
- Responsible for licensing Virtual Asset Service Providers (VASPs).
- Determines which cryptocurrencies can be listed and traded by licensed entities.
- Enforces AML/CFT regulations.

III. Important Legislation and Regulations:

Resolution 215/2021:
- Recognized cryptocurrencies and established guidelines for their use in commercial transactions and investments.
- Defined virtual assets as digital representations of value that can be commercialized or transferred digitally and used for payments or investments.
- Outlined the process for licensing VASPs.
- Explicitly stated that transactions with virtual assets between individuals were not prohibited.
Resolution 89/2022:
- Detailed the requirements and procedures for obtaining licenses for VASPs.
- Confirmed that the BCC is the only institution able to approve VASP licenses.
- Requires all license holders to comply with BCC rulings regarding AML/CFT and weapons proliferation.

IV. Requirements for Compliance (for VASPs):

Licensing: Entities providing services related to cryptocurrencies (e.g., exchanges, custody services) must obtain a license from the BCC.
- Licenses are granted for an initial one-year period, extendable for a second year.
AML/CFT Compliance: Licensed VASPs must comply with BCC rulings concerning anti-money laundering (AML), combating the financing of terrorism (CFT), and weapons proliferation.
KYC Compliance: KYC/AML compliance expectations are in place for exchange platforms.
Reporting Obligations: Reporting obligations are in place for exchange platforms.
Legality, Socioeconomic Interest, Probity and Experience: The BCC evaluates license applications based on legality, socioeconomic interest, and the applicant's probity and experience.

V. Notable Restrictions or Limitations:

U.S. Sanctions: Major international cryptocurrency exchanges often do not officially operate in Cuba due to U.S. sanctions.
Limited Exchange Options: This leads to the continued use of peer-to-peer (P2P) trading, often facilitated through platforms like Telegram and WhatsApp.
BCC Control over Listed Assets: The BCC has the authority to determine which specific cryptocurrencies or digital assets can be listed and traded by licensed entities in Cuba.
Government Warnings: The government has issued warnings about the risks associated with cryptocurrencies, such as volatility and their potential use in fraudulent schemes.

VI. Recent Developments or Changes:

Resolution 215/2021 (Effective September 2021): Legalized the use of virtual assets for commercial transactions and investments.
Resolution 89/2022 (April 2022): Further detailed the requirements and procedures for obtaining licenses for VASPs.

Full Analysis Report

Retail Cryptocurrency Trading Status in Cuba

Report Date: June 26, 2025

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Current Status: Allowed-Regulated

2. Detailed Narrative Explanation:

Retail cryptocurrency trading is legally permitted in Cuba but is subject to a regulatory framework established by the Central Bank of Cuba (BCC). This framework was primarily introduced through Resolution 215/2021, which recognized cryptocurrencies and outlined the process for licensing virtual asset service providers (VASPs). Subsequent regulations have further clarified these initial provisions.

Historically, the Cuban government's stance was one of observation as cryptocurrency usage grew organically, partly as a means to bypass U.S. sanctions and facilitate remittances. The increasing popularity and the potential for financial circumvention, alongside the inherent risks of unregulated digital assets, prompted the authorities to establish a formal regulatory environment.

Resolution 215/2021, effective from September 2021, allows the use of virtual assets for commercial transactions and investments. It defines virtual assets and identifies activities that require a license from the BCC, including the exchange of virtual assets for legal tender, exchange between different virtual assets, transfer of virtual assets, and custody or administration of virtual assets. This means that individuals can legally buy, sell, and hold cryptocurrencies, but entities wishing to provide services related to these activities must obtain prior authorization.

In April 2022, the BCC issued Resolution 89/2022, which further detailed the requirements and procedures for obtaining licenses for VASPs. These licenses are granted for an initial one-year period, extendable for a second year, highlighting the experimental and evolving nature of cryptocurrency regulation in the country. The BCC is responsible for evaluating license applications based on legality, socioeconomic interest, and the applicant's probity and experience.

The regulations also emphasize the prevention of illicit activities. Licensed VASPs are required to comply with BCC rulings concerning anti-money laundering (AML), combating the financing of terrorism (CFT), and weapons proliferation. The BCC also has the authority to determine which specific cryptocurrencies or digital assets can be listed and traded by licensed entities in Cuba.

Despite these regulations, the practical landscape has nuances. Due to U.S. sanctions, major international cryptocurrency exchanges often do not officially operate in Cuba. This has led to the continued use of peer-to-peer (P2P) trading, often facilitated through platforms like Telegram and WhatsApp, alongside any locally licensed entities that may emerge. The government, while regulating the space, has also issued warnings about the risks associated with cryptocurrencies, such as volatility and their potential use in fraudulent schemes.

Therefore, while individual Cubans are permitted to engage with cryptocurrencies, the environment is regulated, with the Central Bank overseeing the activities of service providers and aiming to mitigate associated risks.

3. Specific, Relevant Text Excerpts:

Resolution 215/2021 (as summarized by the Library of Congress): "On August 26, 2021, Cuba's government published Resolución 215/2021, a directive issued by its Central Bank that establishes guidelines applicable to the use of virtual assets (such as cryptocurrency) in commercial transactions and to the licenses that may be issued to providers of services pertaining to such assets."
Resolution 215/2021 (as summarized by the Library of Congress): "The directive defines virtual assets as the digital representation of value that can be commercialized or transferred digitally and used for payments or investments. It also defines providers of virtual assets as any individual or company that is engaged in certain cryptocurrency transactions, including: The exchange of virtual assets to legal tender. The exchange between one or more types of virtual assets. The transfer of virtual assets. Custody or administration of virtual assets. Providing financial services related to the sale of a virtual asset."
Resolution 215/2021 (as reported by Cointelegraph): "With crypto legally recognized by the BCC, Bitcoin and other cryptocurrencies can now be used for commercial transactions and investments in Cuba."
Resolution 215/2021 (as reported by Al Jazeera): "A resolution published in the Official Gazette on Thursday said the central bank will set rules on cryptocurrencies and determine how to license providers of related services within the communist state."
Resolution 89/2022 (as reported by The Caribbean Council): "Cuba's Central Bank (BCC) has published a decree law that establishes the procedures that those providing virtual assets (cryptocurrencies) must comply with to operate legally in the country... The new law makes clear the basis on which individuals and companies will be able in future to operate cryptocurrency exchanges and custody services. It confirms that the BCC is the only institution able to approve virtual asset service provider licenses to individuals or companies."
Resolution 89/2022 (as reported by The Caribbean Council): "The regulation requires all license holders to comply with BCC rulings in relation to the prevention, detection, and combating of money laundering, terrorism financing, weapons proliferation, and other similar concerns."
Negolution, discussing Resolution 215/2021: "Actually, the first regulatory effort in the field of cryptoassets dates back to Resolution 215/2021. There, it was explicitly stated that transactions with virtual assets between individuals were not prohibited."
UPay Blog, on Resolution 215: "This pioneering resolution made it legally possible to use cryptocurrencies as a legal mode of payment and allowed approved virtual asset service providers to conduct business within the country."
FinanceDevil, on the regulatory landscape: "The Central Bank of Cuba (BCC) has established basic guidelines for cryptocurrency operations: Recognition of cryptocurrencies as a valid form of payment. Requirements for exchange platforms. KYC/AML compliance expectations. Reporting obligations."

4. Direct, Accessible URL Links to Sources:

** Library of Congress - Cuba: Central Bank Issues Directive on Cryptocurrency:** https://www.loc.gov/item/global-legal-monitor/2021-10-04/cuba-central-bank-issues-directive-on-cryptocurrency/
** Coincub - Best Crypto Exchange Cuba:** https://coincub.com/country/cuba-crypto-guide/
** Al Jazeera - Cuba to recognise, regulate cryptocurrency:** https://www.aljazeera.com/news/2021/8/27/cuba-to-recognise-regulate-cryptocurrency
** Andersen - Cryptocurrencies, a new resource available to businesses in Cuba:** https://www.andersen.com/en/insights/market-updates/cryptocurrencies-a-new-resource-available-to-businesses-in-cuba/
** The Caribbean Council - Central Bank to licence cryptocurrency operations:** https://www.caribbean-council.org/central-bank-to-licence-cryptocurrency-operations/
** UPay Blog - Crypto Adoption Around the World: Cuba:** https://upay.inc/blog/crypto-adoption-around-the-world-cuba
** Cointelegraph - Cuba's cryptocurrency regulations take effect:** https://cointelegraph.com/news/cuba-s-cryptocurrency-regulations-take-effect
** U.S. - Cuba Trade and Economic Council, Inc. - Cuba Central Bank Moving Nearer To Regulations For Cryptocurrencies:** https://www.cubatrade.org/blog/2021/8/26/reuters-cuba-to-recognize-and-regulate-cryptocurrencies-for-payments (Note: This page contains excerpts and links to the Official Gazette)
** AP News - Cuba to recognize -- and regulate -- cryptocurrencies:** https://apnews.com/article/technology-business-cuba-caribbean-cryptocurrency-221ca3e248a3c7f83ab20d9399ef17e1
** Negolution - Cryptocurrencies in Cuba: What changes with the regulation of their use?:** https://negolution.com/en/cryptocurrencies-in-cuba-what-changes-with-the-regulation-of-their-use/
** CoinMarketCap - Cuban Government Allows Central Bank to Legalize Crypto Economy:** https://coinmarketcap.com/community/articles/60d3a5e6a3db8226c0f8e5a3/
** FinanceDevil - Crypto Trading Market for Cuba in 2025:** https://financedevil.com/crypto-trading-market-for-cuba/
** Quora - Which crypto exchange works in Cuba?:** https://www.quora.com/Which-crypto-exchange-works-in-Cuba
** Journal of Cultural Economy (Taylor & Francis Online) - Tokens of survival: the rise of crypto gaming in Cuba’s inflationary economy:** https://www.tandfonline.com/doi/full/10.1080/17530350.2024.2435133 (Note: Access may require subscription, but abstract and some content are often available)

Disclaimer: This report is based on information available up to the report date. Financial regulations can change, and it is advisable to consult with qualified legal and financial professionals for the most current and specific advice.

## Retail Cryptocurrency Trading Status in Cuba

**Report Date:** June 26, 2025

**Topic:** Retail_Trading_Status

**Description:** Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

---

**1. Current Status:** Allowed-Regulated

---

**2. Detailed Narrative Explanation:**

Retail cryptocurrency trading is legally permitted in Cuba but is subject to a regulatory framework established by the Central Bank of Cuba (BCC). This framework was primarily introduced through **Resolution 215/2021**, which recognized cryptocurrencies and outlined the process for licensing virtual asset service providers (VASPs). Subsequent regulations have further clarified these initial provisions.

Historically, the Cuban government's stance was one of observation as cryptocurrency usage grew organically, partly as a means to bypass U.S. sanctions and facilitate remittances. The increasing popularity and the potential for financial circumvention, alongside the inherent risks of unregulated digital assets, prompted the authorities to establish a formal regulatory environment.

Resolution 215/2021, effective from September 2021, allows the use of virtual assets for commercial transactions and investments. It defines virtual assets and identifies activities that require a license from the BCC, including the exchange of virtual assets for legal tender, exchange between different virtual assets, transfer of virtual assets, and custody or administration of virtual assets. This means that individuals can legally buy, sell, and hold cryptocurrencies, but entities wishing to provide services related to these activities must obtain prior authorization.

In April 2022, the BCC issued **Resolution 89/2022**, which further detailed the requirements and procedures for obtaining licenses for VASPs. These licenses are granted for an initial one-year period, extendable for a second year, highlighting the experimental and evolving nature of cryptocurrency regulation in the country. The BCC is responsible for evaluating license applications based on legality, socioeconomic interest, and the applicant's probity and experience.

The regulations also emphasize the prevention of illicit activities. Licensed VASPs are required to comply with BCC rulings concerning anti-money laundering (AML), combating the financing of terrorism (CFT), and weapons proliferation. The BCC also has the authority to determine which specific cryptocurrencies or digital assets can be listed and traded by licensed entities in Cuba.

Despite these regulations, the practical landscape has nuances. Due to U.S. sanctions, major international cryptocurrency exchanges often do not officially operate in Cuba. This has led to the continued use of peer-to-peer (P2P) trading, often facilitated through platforms like Telegram and WhatsApp, alongside any locally licensed entities that may emerge. The government, while regulating the space, has also issued warnings about the risks associated with cryptocurrencies, such as volatility and their potential use in fraudulent schemes.

Therefore, while individual Cubans are permitted to engage with cryptocurrencies, the environment is regulated, with the Central Bank overseeing the activities of service providers and aiming to mitigate associated risks.

---

**3. Specific, Relevant Text Excerpts:**

*   **Resolution 215/2021 (as summarized by the Library of Congress):** "On August 26, 2021, Cuba's government published Resolución 215/2021, a directive issued by its Central Bank that establishes guidelines applicable to the use of virtual assets (such as cryptocurrency) in commercial transactions and to the licenses that may be issued to providers of services pertaining to such assets."
*   **Resolution 215/2021 (as summarized by the Library of Congress):** "The directive defines virtual assets as the digital representation of value that can be commercialized or transferred digitally and used for payments or investments. It also defines providers of virtual assets as any individual or company that is engaged in certain cryptocurrency transactions, including: The exchange of virtual assets to legal tender. The exchange between one or more types of virtual assets. The transfer of virtual assets. Custody or administration of virtual assets. Providing financial services related to the sale of a virtual asset."
*   **Resolution 215/2021 (as reported by Cointelegraph):** "With crypto legally recognized by the BCC, Bitcoin and other cryptocurrencies can now be used for commercial transactions and investments in Cuba."
*   **Resolution 215/2021 (as reported by Al Jazeera):** "A resolution published in the Official Gazette on Thursday said the central bank will set rules on cryptocurrencies and determine how to license providers of related services within the communist state."
*   **Resolution 89/2022 (as reported by The Caribbean Council):** "Cuba's Central Bank (BCC) has published a decree law that establishes the procedures that those providing virtual assets (cryptocurrencies) must comply with to operate legally in the country... The new law makes clear the basis on which individuals and companies will be able in future to operate cryptocurrency exchanges and custody services. It confirms that the BCC is the only institution able to approve virtual asset service provider licenses to individuals or companies."
*   **Resolution 89/2022 (as reported by The Caribbean Council):** "The regulation requires all license holders to comply with BCC rulings in relation to the prevention, detection, and combating of money laundering, terrorism financing, weapons proliferation, and other similar concerns."
*   **Negolution, discussing Resolution 215/2021:** "Actually, the first regulatory effort in the field of cryptoassets dates back to Resolution 215/2021. There, it was explicitly stated that transactions with virtual assets between individuals were not prohibited."
*   **UPay Blog, on Resolution 215:** "This pioneering resolution made it legally possible to use cryptocurrencies as a legal mode of payment and allowed approved virtual asset service providers to conduct business within the country."
*   **FinanceDevil, on the regulatory landscape:** "The Central Bank of Cuba (BCC) has established basic guidelines for cryptocurrency operations: Recognition of cryptocurrencies as a valid form of payment. Requirements for exchange platforms. KYC/AML compliance expectations. Reporting obligations."

---

**4. Direct, Accessible URL Links to Sources:**

*   ** Library of Congress - Cuba: Central Bank Issues Directive on Cryptocurrency:** [https://www.loc.gov/item/global-legal-monitor/2021-10-04/cuba-central-bank-issues-directive-on-cryptocurrency/](https://www.loc.gov/item/global-legal-monitor/2021-10-04/cuba-central-bank-issues-directive-on-cryptocurrency/)
*   ** Coincub - Best Crypto Exchange Cuba:** [https://coincub.com/country/cuba-crypto-guide/](https://coincub.com/country/cuba-crypto-guide/)
*   ** Al Jazeera - Cuba to recognise, regulate cryptocurrency:** [https://www.aljazeera.com/news/2021/8/27/cuba-to-recognise-regulate-cryptocurrency](https://www.aljazeera.com/news/2021/8/27/cuba-to-recognise-regulate-cryptocurrency)
*   ** Andersen - Cryptocurrencies, a new resource available to businesses in Cuba:** [https://www.andersen.com/en/insights/market-updates/cryptocurrencies-a-new-resource-available-to-businesses-in-cuba/](https://www.andersen.com/en/insights/market-updates/cryptocurrencies-a-new-resource-available-to-businesses-in-cuba/)
*   ** The Caribbean Council - Central Bank to licence cryptocurrency operations:** [https://www.caribbean-council.org/central-bank-to-licence-cryptocurrency-operations/](https://www.caribbean-council.org/central-bank-to-licence-cryptocurrency-operations/)
*   ** UPay Blog - Crypto Adoption Around the World: Cuba:** [https://upay.inc/blog/crypto-adoption-around-the-world-cuba](https://upay.inc/blog/crypto-adoption-around-the-world-cuba)
*   ** Cointelegraph - Cuba's cryptocurrency regulations take effect:** [https://cointelegraph.com/news/cuba-s-cryptocurrency-regulations-take-effect](https://cointelegraph.com/news/cuba-s-cryptocurrency-regulations-take-effect)
*   ** U.S. - Cuba Trade and Economic Council, Inc. - Cuba Central Bank Moving Nearer To Regulations For Cryptocurrencies:** [https://www.cubatrade.org/blog/2021/8/26/reuters-cuba-to-recognize-and-regulate-cryptocurrencies-for-payments](https://www.cubatrade.org/blog/2021/8/26/reuters-cuba-to-recognize-and-regulate-cryptocurrencies-for-payments) (Note: This page contains excerpts and links to the Official Gazette)
*   ** AP News - Cuba to recognize -- and regulate -- cryptocurrencies:** [https://apnews.com/article/technology-business-cuba-caribbean-cryptocurrency-221ca3e248a3c7f83ab20d9399ef17e1](https://apnews.com/article/technology-business-cuba-caribbean-cryptocurrency-221ca3e248a3c7f83ab20d9399ef17e1)
*   ** Negolution - Cryptocurrencies in Cuba: What changes with the regulation of their use?:** [https://negolution.com/en/cryptocurrencies-in-cuba-what-changes-with-the-regulation-of-their-use/](https://negolution.com/en/cryptocurrencies-in-cuba-what-changes-with-the-regulation-of-their-use/)
*   ** CoinMarketCap - Cuban Government Allows Central Bank to Legalize Crypto Economy:** [https://coinmarketcap.com/community/articles/60d3a5e6a3db8226c0f8e5a3/](https://coinmarketcap.com/community/articles/60d3a5e6a3db8226c0f8e5a3/)
*   ** FinanceDevil - Crypto Trading Market for Cuba in 2025:** [https://financedevil.com/crypto-trading-market-for-cuba/](https://financedevil.com/crypto-trading-market-for-cuba/)
*   ** Quora - Which crypto exchange works in Cuba?:** [https://www.quora.com/Which-crypto-exchange-works-in-Cuba](https://www.quora.com/Which-crypto-exchange-works-in-Cuba)
*   ** Journal of Cultural Economy (Taylor & Francis Online) - Tokens of survival: the rise of crypto gaming in Cuba’s inflationary economy:** [https://www.tandfonline.com/doi/full/10.1080/17530350.2024.2435133](https://www.tandfonline.com/doi/full/10.1080/17530350.2024.2435133) (Note: Access may require subscription, but abstract and some content are often available)

---
**Disclaimer:** This report is based on information available up to the report date. Financial regulations can change, and it is advisable to consult with qualified legal and financial professionals for the most current and specific advice.

Web Sources (14)

Sources discovered via web search grounding

Search queries used (6)

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Cuba central bank cryptocurrency
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Resolution 215/2021 Central Bank of Cuba cryptocurrency

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