Why Cuba Matters

The Cuban diaspora is one of the largest in Latin America relative to the home population: more than two million Cuban-Americans concentrated in Florida, a large and growing Cuban-Spanish community, and newer settlements in Mexico, Panama and across the region. Multi-generational Cuban-American, Cuban-Spanish and other diaspora clients have specific cross-border needs, usually around US or Spanish property, remittances and long-term financial support for family on the island, and increasingly around a second nationality for the next generation.

Cuba matters to FTR entirely on that side. There is no planning to be done inside Cuba: foreigners cannot own property outside a handful of approved developments, private companies are reserved for resident Cubans, the banking system does not connect to the world, and the tax system is irrelevant to anyone FTR would advise. What matters is the sanctions perimeter around Cuban-connected people and money, which reaches further than most clients realise, and the migration and nationality routes that have opened and closed since 2021.

The recent emigration wave has also produced a new client type: professionals who left in 2022 or 2023, hold a Cuban passport and perhaps a Spanish or Mexican residency, have family and a house in Havana, and are beginning to earn and save abroad. For them the questions are nationality, banking and how to help family lawfully.

Visa and Residency Routes

Into Cuba: tourists receive a 90-day stay, extendable to 180 for Canadians, and foreigners obtain temporary residence only through employment with an approved entity, marriage to a Cuban or an approved investment under Ley 118. None of these is a route FTR would use, and Cuba cannot serve as a retirement, remote-work or Plan-B residency.

Out of Cuba, the routes that matter: the US Cuban Adjustment Act of 1966 remains in force and allows a Cuban admitted or paroled into the United States to apply for permanent residence after a year, but the humanitarian parole programme that fed it was terminated in 2025 and entry now depends on family petitions, employment or the ordinary visa system. Spain naturalises Ibero-Americans after two years' legal residence, and the Ley de Memoria Democrática route for grandchildren of Spanish emigrants, which drew tens of thousands of applications through the Havana consulate, closed to new applications in October 2025; Cubans who obtained Spanish nationality through it now hold an EU passport and are among the easiest Cuban-born clients to bank. Mexico and Panama require visas and offer temporary residence on the usual employment and economic-solvency grounds; Panama's banks are the obstacle, not its immigration service.

Cuban nationality follows the client. A Cuban-born person must enter Cuba on a Cuban passport whatever other nationality they hold, the passport costs several hundred dollars abroad and is now valid for ten years without the old two-yearly extensions. The 2025 migration law replaced the emigrado status and the 24-month absence rule with a residence-abroad category, and its effect on the property rights of Cubans living abroad is still being worked out in implementing rules.

Tax Peculiarities and Traps

Cuban tax does not catch FTR's clients; US sanctions law does.

Who is a person subject to US jurisdiction. The Cuban Assets Control Regulations apply to US citizens and permanent residents wherever they live, to entities organised in the United States, and to any entity, wherever organised, that is owned or controlled by such persons. A Cuban-American's Panamanian SA is subject to the regulations in full. It may not hold Cuban property, invest in a Cuban business, pay a Cuban entity or receive Cuban-source funds except under a general or specific OFAC licence, and a Panamanian bank with a US correspondent will apply the same rule whether or not the client is a US person.

Blocked and unblocked nationals. A Cuban national resident in Cuba is a blocked person for US purposes: their property in US jurisdiction is frozen and no US-connected institution may deal with them. A Cuban national who has taken up permanent residence in a third country is unblocked by general licence and can be a client, subject to screening and a provenance file. The distinction is residence, not passport, and it must be documented.

Helms-Burton. Title III allows US claimants to sue anyone, of any nationality, who trafficks in property confiscated after 1959, and suits have run against hotel groups, cruise lines and their partners since the suspension was lifted in 2019. Title IV bars traffickers and their families from the United States. A Cuban-Spanish client investing in an approved Cuban tourism or Mariel venture takes this exposure personally, and the EU Blocking Statute does not remove it.

Inheritance from Cuba. Cuban property rules have historically excluded emigrant heirs from residential property, and a US person generally needs an OFAC licence to receive property from Cuba. The result is that a Cuban-American inheriting a Havana house often cannot lawfully own it, sell it or take the proceeds; the practical answer is a transfer to a resident relative in life, and the timing of the 2025 law's implementing rules matters.

Remittances. Family remittances by US persons are permitted under a general licence with counterparty limits, and payments to or through Restricted List entities are prohibited; the formal channels have been suspended and restored more than once, and most support reaches families through carriers and stablecoins. Legitimate as those are for the recipient, they leave the sender with no records, which matters at a bank later.

The Structural Layer

For a Cuban-born client resident and unblocked in a third country, FTR's default of a Panamanian Private Interest Foundation owning a Panamanian SA, with a modest director's salary paid where they live, fits without modification for non-Cuban assets, provided the sanctions screening is done first and the client's status as a US person or not is fixed at the outset, because it determines what the structure may ever touch. For a US-person client the entire structure is subject to the Cuban Assets Control Regulations and is built to have no Cuban connection at all; a non-US client's structure may hold Cuban-related assets only within the Helms-Burton perimeter and only if the bank will accept it, which in practice means it should not.

Cuban assets stay outside the structure in every case. Nothing in Cuba can be held through a foreign entity, and Cuban family support is handled as personal remittances under licence, not through the company.

The home-country rules that bite are those of the residence country: US CFC and foreign trust rules for Cuban-Americans, Spain's Modelo 720 and CFC regime for Cuban-Spaniards, and so on through the profile for that country. Cuban CFC rules do not exist in any meaningful sense.

Info-Sharing Reality (CRS and FATCA)

Cuba is outside CRS and outside FATCA. Cuban banks report to no one and receive nothing, and a Cuban resident's foreign accounts are invisible to the Cuban state. That is worthless as a planning fact, because no Cuban resident can hold accounts with any institution connected to the US financial system, and the diaspora are reported in full by their residence country: Cuban-Americans through FBAR and Form 8938, Cuban-Spaniards through Modelo 720 and CRS exchanges from every jurisdiction where they hold accounts. There is no Chinese-HNW or Plan-B privacy lens here; the only relevant reporting question is the sanctions screening a bank performs on a Cuban place of birth.

Banking Reality

Inside Cuba, Banco Metropolitano, Banco Popular de Ahorro, Bandec and Banco Financiero Internacional serve residents in CUP, MLC and now limited dollars; there is no correspondent access to the US system, most European banks have withdrawn, US-issued cards do not work, and no foreigner should keep more than pocket money in the country. Outside Cuba, a Cuban place of birth triggers enhanced due diligence in every bank with a US correspondent, which is every bank FTR uses. Panamanian banks decline most Cuban nationals without Panamanian residency and a documented source of funds. A Cuban-born client holding a Spanish or US passport with third-country residence and a clean provenance file banks normally after a longer onboarding; a client resident in Cuba cannot be banked by FTR at all.

Cost of Doing Business

A Cuban entity is not available to FTR's clients: MIPYMEs are reserved for resident Cubans, and foreign investment requires government approval of a joint venture or wholly foreign company under Ley 118, typically inside the Mariel Special Development Zone, on a timescale of years. For the diaspora client the comparison is between the residence country's entity and the Panamanian default: a Panamanian SA runs roughly USD 1,500 to 2,500 to establish and USD 1,000 to 1,800 a year; Singapore about three times the Panamanian setup at USD 4,500 to 7,500 with USD 4,000 to 8,000 annual compliance; a Spanish SL USD 1,500 to 3,000 to form and USD 3,000 to 6,000 a year; a Florida LLC a few hundred dollars to form and USD 1,000 to 3,000 a year. The Cuban-specific cost is the sanctions and provenance work, which adds professional time to every onboarding.

Cost of Living

Monthly, in dollars, for Havana's Vedado and Miramar, for foreigners on posting or family members supported from abroad.

Lean: USD 1,000 to 1,500: a rented apartment USD 400 to 700, food largely from private and dollar shops, a generator or battery system, mobile data at high cost.

Comfortable: USD 2,500 to 4,000: a house in Miramar USD 1,200 to 2,000, private transport, imported food, medicines sourced abroad, backup power and water.

HNW: not a meaningful tier; diplomats and joint-venture executives live on employer packages with evacuation cover.

Cultural and Practical Considerations

Cuba is a place clients come from and send money to, and this section is written for visits and for supporting family, not for relocation.

Daily life. The grid has collapsed nationally several times since October 2024 and rolling blackouts of many hours a day are normal outside Havana; water, fuel, medicine and basic food are in chronic short supply; public healthcare, once the state's showpiece, is short of staff, drugs and equipment, and dengue and other outbreaks recur. Anyone with a chronic condition brings their own supplies. Hurricanes are an annual risk.

Politics and security. A one-party state with dissent criminalised under the 2022 penal code and the cybersecurity decree; the July 2021 protests were followed by long sentences. Violent crime is low by regional standards; property crime and scams around foreigners are common. A diaspora client with a public political profile should assume they will be refused entry or questioned.

Women and LGBT residents. Legal equality for women is long established and practical safety is better than in most of the region. The 2022 Family Code legalised same-sex marriage and adoption, which is more than Peru, Venezuela or most of Central America offer; the state's tolerance does not extend to independent LGBT activism.

Language, integration, religion. Spanish only. Cubans are sociable and the diaspora's family ties are dense; Catholicism, Afro-Cuban religion and secularism coexist without dietary constraint. Integration is not the issue; leaving is.

Bureaucracy. Slow, discretionary and paper-based; consular services abroad are expensive and unpredictable, and every Cuban document needed for a foreign residency or nationality file takes months.

For High Net Worth (HNW) Families and Investors

Cuban-born clients resident abroad: sanctions status first, then the default structure for non-Cuban assets, with residency and nationality routes chosen for the next generation; Spanish nationality where any ancestry allows it.

For Multinational and online business owners.

Treated under their residence country's profile; the Cuban connection adds screening and a rule that the business never touches the island.

For Retirees

Not applicable; Cuba is not a residence option and the diaspora's retirees are handled under the United States, Spain or Panama profiles.

Common Traps

Any structure, account or investment for a person resident in Cuba; FTR cannot act.

A Cuban-American's foreign company doing anything with Cuba; the company is a US person for sanctions purposes.

A Cuban-Spanish investor in a Cuban hotel or Mariel venture expecting European law to shield them; Helms-Burton exposure is personal and survives the Blocking Statute.

Assuming absence from CRS means anything; every diaspora client is reported by their residence country.

Undocumented remittances or carried cash surfacing later as a source of funds; the bank will not accept it.

Expecting to inherit and sell a Havana house from abroad; the property and licensing rules have been designed to prevent exactly that.

Next Steps

Cuban-connected planning starts with a sanctions status determination for every family member, then provenance, then residency and structure. Book a scoping call and bring passports, residence permits and any record of remittances.

Important note: General information. Not personal tax, legal, or financial advice. Speak to a qualified adviser at FTR or elsewhere before acting.