Private banks built on sanctioned ground

Cuba's reform authorises private corporate banks under Banco Central de Cuba supervision on the same regulatory terms as state banks, plus private non-bank lenders for microcredit ¹. The Banco Central de Cuba is Cuba's central bank, the regulator the reform makes supervisor of the new sector. Private actors may now hold and withdraw dollars from accounts without forced conversion to pesos ², a tacit admission that the peso no longer functions as a store of value. The package establishes a cryptocurrency framework for domestic and cross-border transfers, licenses the state mobile-payments platform Transfermovil as a non-bank financial institution, and creates private exchange houses and last-mile payment agents, the final handlers delivering diaspora remittances to recipients ³.

That last measure ends the monopoly on diaspora flows held by GAESA, the military business conglomerate that controls roughly 60% of Cuba's hard-currency revenue and has channelled remittances since the Visa and Mastercard card rails went dark in early June . The reform also commits to "successive devaluations", step-by-step official weakenings of the peso, of the rate now 555 pesos to the dollar, toward the informal 670 ⁴. That 115-peso gap is a 21% premium, which in practice means a household paid in pesos loses a fifth of its purchasing power the moment it needs dollars for imported food or medicine.

The workaround has a structural flaw. GAESA is itself a designated entity on the US Specially Designated Nationals list, a blacklist barring any dollar-clearing firm from dealing with it, and the same designations that named GAESA's security ministries drove the card and hotel exits this fortnight. Any new private channel that touches GAESA infrastructure inherits the same legal exposure to US secondary sanctions. The devaluation commitment carries its own precedent risk: the January 2021 Tarea Ordenamiento currency unification saw its single official rate collapse within months as the informal market reasserted a faster parallel rate, fuelling inflation. A managed step-down chasing an informal rate that moves faster than the official one can follow is the same trap, now larger.