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Asset tokenization in Cuba

In Cuba there is no established route to offer tokenized securities to the public: an MSME's membership interests cannot be negotiable instruments, and the Central Bank's virtual asset licenses leave securities out. We review with you the right and the structure that can be prepared.

Tell us about your project
Blockchain development in Cuba: dotted globe with the country marked by its flag

They trust Metlabs to tokenize their assets

Didit - Metlabs client
Cool Farming - Metlabs client
Criptorent - Metlabs client
DDC Developments - Metlabs client
Stripe - Metlabs client
Cox Energy - Metlabs client
Bridge - Metlabs client
Casa de Outeiro - Metlabs client
Divend - Metlabs client
Onyze - Metlabs client
Ursus-3 Capital - Metlabs client
Tokenizante - Metlabs client
Gofaizen & Sherle - Metlabs client
LAOLA Surf Camp - Metlabs client
CertiK - Metlabs client
Briga - Metlabs client
Hacken - Metlabs client
Sanmortech - Metlabs client
ECIJA Abogados - Metlabs client
TOK4REAL - Metlabs client
Brickeny - Metlabs client
IDC Valores - Metlabs client
SoulBit - Metlabs client
byTask - Metlabs client
Humantial - Metlabs client
ATH21 - Metlabs client
Astria Capital - Metlabs client
Catenon - Metlabs client
Arborem - Metlabs client
Padel Sport Club - Metlabs client
NET2FLY - Metlabs client
The White Capital - Metlabs client
SHAMUSIC - Metlabs client
Slide.fun - Metlabs client
Sumsub - Metlabs client
Unodeuno - Metlabs client
Comunidad Solar - Metlabs client
Synergyland - Metlabs client
Didit - Metlabs client
Cool Farming - Metlabs client
Criptorent - Metlabs client
DDC Developments - Metlabs client
Stripe - Metlabs client
Cox Energy - Metlabs client
Bridge - Metlabs client
Casa de Outeiro - Metlabs client
Divend - Metlabs client
Onyze - Metlabs client
Ursus-3 Capital - Metlabs client
Tokenizante - Metlabs client
Gofaizen & Sherle - Metlabs client
LAOLA Surf Camp - Metlabs client
CertiK - Metlabs client
Briga - Metlabs client
Hacken - Metlabs client
Sanmortech - Metlabs client
ECIJA Abogados - Metlabs client
TOK4REAL - Metlabs client
Brickeny - Metlabs client
IDC Valores - Metlabs client
SoulBit - Metlabs client
byTask - Metlabs client
Humantial - Metlabs client
ATH21 - Metlabs client
Astria Capital - Metlabs client
Catenon - Metlabs client
Arborem - Metlabs client
Padel Sport Club - Metlabs client
NET2FLY - Metlabs client
The White Capital - Metlabs client
SHAMUSIC - Metlabs client
Slide.fun - Metlabs client
Sumsub - Metlabs client
Unodeuno - Metlabs client
Comunidad Solar - Metlabs client
Synergyland - Metlabs client
Current framework

Can assets be tokenized in Cuba?

Today there is no established route to offer tokenized securities to the Cuban public. Private companies are S.R.L.s whose membership interests cannot be negotiable instruments and are assigned before a notary, foreign investment needs a state Authorization case by case, and the Central Bank's virtual asset licenses leave securities out.

2024

year of Decree-Law 88, which prohibits representing an MSME's membership interests as negotiable instruments

Official Gazette · DL 88/2024

3

forms of foreign investment, all with an Authorization from the Council of State, the Council of Ministers or an empowered agency

Law 118, arts. 13 and 21

2022

year of Central Bank Resolution 89, which grants virtual asset licenses one by one and leaves securities out

BCC · Resolution 89/2022
What gets tokenized

Debt, equity and revenue: what gets tokenized in Cuba

Almost every tokenized issuance represents one of these three rights against the issuer. In Cuba, the rules reviewed provide no public offering for any of them: private companies are financed by contract or with new partners, and foreign investment comes in through forms the state authorizes one by one.

RightDebtEquityRevenue
What is issuedContract financingMSME membership interestsEconomic association contract
The investor receivesThe lender advances funds to the company and is repaid under the contract terms, with no negotiable debt security.The partner joins the capital: profit distribution, voting rights and a share of any liquidation.The parties contribute to an authorized for-profit activity and share its results under the contract.
The token enforces
  • Coupon and payment schedule
  • Maturity and redemption
  • Verified investors only
  • Profit distribution
  • Voting rights
  • Transfer restrictions
  • Percentage and calculation base
  • Distribution frequency
  • Term and buyback
IssuerMSME (S.R.L.)MSME (S.R.L.)Parties with an Authorization
RegisterContract and accountsCommercial RegistryAs the Authorization sets
LawDecree-Law 88/2024, art. 10Decree-Law 88/2024, arts. 26 and 62Law 118, arts. 13 and 15
How it is issuedMSMEs and private companies with more than one hundred workers can use any lawful source of financing, but their law does not provide for issuing bonds to the public. Debt is documented as a loan or contract between the parties, and the Central Bank's virtual asset licenses exclude securities.Membership interests cannot be represented as negotiable instruments, partners have a preemption right and every assignment is executed before a notary and recorded in the Commercial Registry. Only Cuban individuals, resident in Cuba or abroad, and permanent foreign residents can be partners. In a joint venture, changing shareholders requires prior approval.The international economic association contract brings domestic and foreign investors together without creating a legal entity, and each party owns its contributions. It needs a state Authorization, as does transferring the rights it grants. It is not an instrument that can be offered to the public.
Regulation

Which regulation applies to tokenization in Cuba?

Regulation guide for Cuba

There is no regime for tokenized securities and, in the rules reviewed, no public securities offering route for private companies. MSMEs are S.R.L.s whose membership interests cannot be negotiable instruments, foreign investment follows Law 118 with a case-by-case Authorization, and the Central Bank licenses virtual assets individually, without including securities.

Central Bank Resolution 89/2022 subjects each license to an assessment of suitability and socioeconomic interest, and the licenses granted are individual and temporary: they do not enable the issuance of tokenized shares, debt or real estate rights. The MSME and foreign investment rules were updated in 2026 and still provide for no public securities offering.

United States sanctions on Cuba are reviewed separately, for each counterparty and provider. What can be prepared is the analysis of the right, the corporate structure and the platform, for when the framework allows it. We coordinate that work with the law firm, and only authorized entities provide the regulated services.

Cuba

Scope
Cuba
Authorities
BCC
Latest regulatory change
Mar 2026

Applicable frameworks

FrameworkApplies toKey authorisations
Resoluciones BCC 215/2021 y 89/2022VASPs in or from CubaIndividual temporary licence, with socioeconomic-interest assessment
Resolución BCC 76/2023Authorised VASPsDGIOF registration and AML controls
Resolución BCC 4/2026Ten named legal entitiesCross-border payments through licensed providers; not a VASP licence

Our legal partners

A&O Shearman - Legal partner logo
Latham & Watkins - Legal partner logo
Willkie Farr & Gallagher - Legal partner logo
Winston & Strawn - Legal partner logo
Penkies - Legal partner logo
ATH21 - Legal partner logo
A&O Shearman - Legal partner logo
Latham & Watkins - Legal partner logo
Willkie Farr & Gallagher - Legal partner logo
Winston & Strawn - Legal partner logo
Penkies - Legal partner logo
ATH21 - Legal partner logo
Methodology

How we tokenize an asset in Cuba, step by step

The four phases of our methodology, adjusted to the Cuban framework: the first two can be done today, and the last two depend on an authorized route to offer the right.

  1. We review the asset's title, encumbrances and cash flows and define with the sponsor which right the token would represent: a loan, membership interests in an MSME or a contribution to an association contract. That sets the vehicle and the authorizations that would need to be obtained.

    Issuance structure of a residential complex in Excel for an asset tokenization project
  2. The law firm assesses the fit with Decree-Law 88, Law 118 and Resolution 89/2022, and reviews the sanctions affecting each counterparty. As long as there is no established route to offer the right as a token, the next phases do not start.

    Word legal opinion classifying the tokens in an asset tokenization, with the law firm's tracked changes
  3. We design the white-label platform and the ERC-3643 tokens with the rules of the right, KYC onboarding and a holder register that mirrors what is recorded in the Commercial Registry, without replacing the notarial deed or the registration.

    Residential project page on a white label asset tokenization platform under the issuer's brand
  4. Fundraising would only start with an authorized route to offer the right. Until that point no offering is prepared and no marketing communication is directed to investors.

    Go-to-market funnel of an asset tokenization issuance in PostHog, from visit to paid subscription
Reviews in Cuba

What do our clients think of Metlabs?

“One of the pioneering firms in web3 solutions, digital assets and tokenization, recognized for its innovation and solid reputation across Spain and Latin America.”

Jorge Corredor
Jorge CorredorLawyer, Rincón Cuéllar & Asociados

“We structured the tokenization of real estate projects with them, and I value the team's ability to understand our corporate needs and genuinely solve them.”

Joan MejíaManager, GLOBYNE

“They advised us on the feasibility of tokenizing real estate assets in Uruguay with direct, cordial treatment. A professional team, responsive and always available.”

Álvaro Silva Santamaría
Álvaro Silva SantamaríaCEO, Sp Inmuebles

“Great professionals at structuring tokenized projects, with technical command and attention to detail that inspire full confidence at every stage of the work.”

Francisco BetancourtVerified Google review

“As a blockchain lawyer, I value their experience and professionalism in consulting and executing tokenization projects. Technology partners you can fully trust.”

Vanessa Rivas
Vanessa RivasBlockchain lawyer, El Salvador

“Great professionals, very attentive to their clients and always mindful of every detail. Working with their team has been a genuine pleasure from start to finish.”

CriptorentVerified Google review

“A very professional yet approachable company that empathizes with your doubts and needs. Highly recommended for entrepreneurs with a tokenization project.”

Javier Espasa
Javier EspasaTokenization entrepreneur

“Exceptional in every sense. From legal support I value their rigor and transparency: working with Metlabs means professionalism, innovation and security.”

Pedro A. Agúndez Méndez
Pedro A. Agúndez MéndezGoogle Local Guide

“Excellent service across blockchain development, asset tokenization and consulting. A very professional team that I recommend wholeheartedly, without reservation.”

José Luis DíazVerified Google review

“I have worked with them on several projects and they are very professional. A guarantee that everything turns out perfectly. Without a doubt, 100% recommended.”

Ignacio Fernández Jiménez
Ignacio Fernández JiménezVerified Google review
Google Reviews
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Platform

What does our white label tokenization platform include?

The investor portal, ERC-3643 tokens and issuer console, under your brand. Out of the box it handles onboarding, signing, payment and distributions; anything else your issuance needs, such as a local payment method or a connection to your bank or custodian, we build on the same platform.

Request a demo
Home page and project catalog of a white label tokenization platform on a laptop and phone
  • Your brand and domainYour visual identity and legal texts across the investor portal.
  • Investor onboardingSign-up, KYC, KYB and AML checks, and a custodial wallet per investor.
  • End-to-end investmentE-signature and payment by SEPA transfer or stablecoin (USDC/EURC).
  • ERC-3643 tokensEvery subscription is issued under the offering's rules.
  • Issuer consoleProjects, investors, reconciliation, distributions and reporting.
  • Compliance and audit trailKYC status per user and an exportable audit log.

Institutional custody, integrated

We integrate custody and key management providers through their APIs, including Fireblocks, BitGo, Coinbase Prime, Anchorage Digital, Copper and Ledger Enterprise. Depending on the provider and model, keys are managed with MPC or multisig so that none depends on a single device. If the token is a security, custody on behalf of clients is provided by an authorized entity.

FAQ

Frequently asked questions about tokenization in Cuba

What we are asked before a project starts.

Talk to our team
  1. Is it legal to tokenize assets in Cuba?

    Today there is no established route to offer tokenized securities to the public. An MSME's membership interests cannot be negotiable instruments, foreign investment requires a state Authorization for each project and the Central Bank's virtual asset licenses do not cover securities. Designing the structure does not authorize offering anything.

  2. Can an MSME's membership interests be tokenized?

    Not as a negotiable security. Decree-Law 88 prohibits representing them as negotiable instruments, partners have a preemption right and every assignment is executed before a notary and recorded in the Commercial Registry. A digital register can show who the partners are, but it does not replace those formalities.

  3. How does a foreign investor enter a Cuban company?

    Through one of the three forms in Law 118: a joint venture, an international economic association contract or a wholly foreign-owned company, always with an Authorization from the Council of State, the Council of Ministers or the empowered agency. In a joint venture, changing shareholders requires prior approval.

  4. Does a Central Bank virtual asset license allow securities to be tokenized?

    No. The scope of Resolution 89/2022 excludes securities and other traditional financial assets, and each license is individual and temporary, with the activities the Central Bank sets. A provider holding a license does not turn a share, a debt or a real estate right into a token that can be offered.

Asset tokenization

Assets we tokenize in Cuba.

Let's talk about your project in Cuba

Tell us which right you want to issue and we will review the structure and what the Cuban framework allows today, without committing to issuance timelines.

Tell us about your project
Where we are

We're your tokenization company in:

Dotted globe showing the Metlabs headquarters in A Coruña and its presence in Andorra
Proa building in A Coruña, headquarters of Metlabs, a blockchain development and tokenization company

Metlabs Offices

Av. García Sabell, 1, Edificio Proa 15009 A Coruña, Spain

As featured in

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