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The Cuban government published on February 25 in the Extraordinary Official Gazette No. 32 Agreement 10216/2025, a regulation that governs electronic commerce when payments are made to or from abroad in foreign currencies.
The regulation was approved on August 27, 2025, but its entry into force will be 60 days after its publication. It establishes a mandatory framework for natural persons, small and medium-sized enterprises, self-employed workers, legal entities, and operators of technological platforms that manage sales to Cuba with payments in dollars or other foreign currencies.
Greater control of the Central Bank of Cuba and the financial system
The Agreement grants the Central Bank of Cuba (BCC) a central role: it will be the entity responsible for authorizing who can receive payments from abroad and for establishing the applicable rules for international payment gateways.
One of the most important points is that the income generated from e-commerce should be primarily routed to accounts in Cuban banks or to external financial mechanisms linked to the country.
Currency operations cannot be managed freely outside of the national banking system. Additionally, the taxes associated with these operations must be paid in foreign currency, not in Cuban pesos (CUP).
New obligations for platforms and sellers
The regulation imposes additional requirements on those operating in this segment. Vendors must register or update their activity in the Central Commercial Register, register the platforms with the Ministry of Communications, and comply with tax provisions before the National Office of Tax Administration (ONAT).
They must also ensure consumer protection, comply with current regulations regarding cybersecurity, and provide official statistical information to the authorities.
A significant element is the prohibition of selling goods to foreign entities so that they can subsequently market them to recipients in Cuba through e-commerce with payments from abroad. This provision could impact business models based on sales from outside the country with delivery within national territory.
Deadlines and possible implications
The Agreement will come into effect 60 days after its publication in the Official Gazette. Those actors who are already operating will have an additional 30 days to adapt once the Central Bank of Cuba issues the complementary provisions.
In practical terms, the regulation does not introduce foreign currency electronic commerce—an already existing practice—but it does formalize it under a framework of increased financial and tax oversight.
The control of currency flow, the mandatory channeling into the Cuban banking system, and prior authorization from the BCC signify a shift in the regulatory framework for this sector.
The Agreement could create legal tensions for platforms operating from the United States. The regulations of the Office of Foreign Assets Control (OFAC) prohibit individuals and companies under U.S. jurisdiction from engaging in transactions that benefit the Cuban government or its entities.
The Central Bank of Cuba is a state institution, and the obligation to channel income into Cuban banks could be interpreted as a financial operation that directly involves the governmental apparatus.
In the current context of enhanced sanctions by Washington, companies based in the U.S. may face a legal dilemma: comply with the demands of Havana or risk potential violations of U.S. federal regulations.
The actual impact of the measure will depend on how the complementary regulations of the BCC are implemented and the adaptability of the platforms that handle payments from abroad.
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