September 8, 2026
This blog was originally published by Alliance magazine on May 5, 2026.
Civil society in Cuba has operated under a highly restrictive legal and political framework for decades. As civic space contracts around the world, what can philanthropy learn from how support has worked in contexts where formal models fail?
The architecture that international philanthropy depends on, such as trusted intermediaries, functioning banking channels, and a legal environment that permits genuine partnership, is being stress tested faster than our sector is able to innovate. Restrictions on how civil society can operate are becoming more the norm worldwide. Once an extreme example, Cuba is becoming less and less exceptional. As such, lessons on how Cuban civic actors have continued to operate have new salience.
For funders trying to reach communities in Cuba and other highly restrictive legal and political settings, the operational difficulties are only the surface problem. Sanctions regimes and banking restrictions have long complicated the movement of money. But the deeper challenge is structural: the very conditions that make support most urgently needed are the same ones that make formal philanthropy least able to provide it. The communities most in crisis are, almost by design, the furthest from the grant cycle.
Cuba does not yet have a codified ‘foreign agents law’ equivalent to those in other contexts. The 2019 Constitution and subsequent penal code reforms have reinforced the state’s ability to sanction or threaten individuals or groups receiving external funding, often under broad charges like ‘mercenarism’, ‘illicit enrichment’, or actions ‘against the constitutional order’.
Conventional philanthropic models carry embedded assumptions: that money can move, that partners can be identified and cultivated, that impact can be measured against a standard framework, and that compliance and mission will not pull in opposite directions. In Cuba, each of those assumptions is tested, and many fail.
What persists in Cuba are informal systems that sustain people on the ground. Philanthropy continues to be slow to reckon with this reality. What follows is an attempt to examine the trade-offs: between compliance and reach, between measurability and relevance, between the comfort of established practice and the harder discipline of actually getting resources to people who need them.
Risk management can limit reach
Civil society in Cuba operates under a highly restrictive domestic legal and political framework. Cuban law states that international cooperation includes resources from multilateral, bilateral, governmental, and private actors, but the state is the natural beneficiary, as the entity responsible for guaranteeing basic services to the population. All programmes and projects need to be approved by the Ministry of Foreign Trade and Investment.
In many countries, philanthropy relies on a web of local nonprofits, fiscal sponsors, community foundations, and other trusted intermediaries that can receive, manage, and distribute funds responsibly. However, in Cuba, independent NGOs are not formally recognised, and the government has long framed autonomous civic activity—especially when supported from abroad—as a threat to national sovereignty.
In recent years, this posture has hardened, with increased surveillance, detentions, and administrative pressures against independent journalists, activists, and informal groups. While Cuba does not yet have a codified ‘foreign agents law’ equivalent to those in other contexts, the 2019 Constitution and subsequent penal code reforms have reinforced the state’s ability to sanction or threaten individuals or groups receiving external funding, often under broad charges like ‘mercenarism,’ ‘illicit enrichment,’ or actions ‘against the constitutional order.’
What persists in Cuba are informal systems that sustain people on the ground. Philanthropy continues to be slow to reckon with this reality.
Another important barrier is the sanctions environment. United States sanctions on Cuba, first imposed in the early 1960s after the Cuban Revolution, and later reinforced during the Cold War, have evolved into a web of laws and regulations that restrict trade, finance, and travel between the two countries. The inclusion of Cuba in the US list of ‘state sponsors of terrorism’ and legislation such as theHelms–Burton Acteffectively cuts Cuba off from all normal financial relations with Western banks and extends its impact to third-party companies and organisations worldwide.
In practice, this means that working with or in Cuba and in countries facing similar restrictions in Latin America, such as Venezuela and Nicaragua, involves significant logistical and legal hurdles. International transfers are difficult, partnerships often require special licenses, and even routine activities, such as paying suppliers or booking services, become complex.
For funders, these constraints translate into high transaction costs and reputational risk. Frameworks designed to mitigate risk, in effect, prevent resources from reaching those most in need if we continue to use the same one-size-fits-all playbook.
When what counts is not what gets counted
Even in a highly closed context such as Cuba, local actors are receiving support, although it is often through informal channels.
Families and expatriates use remittances as ‘social seed capital’ for community initiatives and sustain small private businesses. Cuban diaspora remittances are estimated at roughly $2–2.5 billion annually.
Volunteer-based transnational activist and exiled networks like Red De Ayuda Humanitaria deliver tonnes of aid each month. These informal networks have grown by building partnerships with other initiatives, organizations, and private businesses, including key airlines operating routes to Cuba. However, the lack of financial, legal, and logistical infrastructure has forced them to suspend larger-scale shipments that require more complex coordination and resources.
Independent creators, artists, and neighbourhood leaders operate without a formal ‘NGO’ status. They utilise digital platforms, crowdfunding, cryptocurrencies, peer-to-peer transfers, and physical ‘mules’ to bring in resources that the banking system refuses to carry.
Independent media outlets and diplomatic bodies have increasingly acted as intermediaries. They redistribute micro-grants, emergency/rapid response funds, scholarships, and targeted mentorship and capacity-building programmes to support activists, artists, independent creators, community-based organisations, and human rights defenders.
Religious institutions and faith-based communities have stepped in with the mechanisms and infrastructure to redistribute resources on the ground. In some cases, universities—often one of the few semi-protected institutional spaces- have played a quiet but important role in convening and knowledge exchange.
Small business owners have built networks among themselves to share resources, pool capital, and sustain operations.
These adaptive forms of giving help communities on the frontline to stay safe, support local initiatives, and move resources into places where formal funding systems cannot easily go.
In closed or shrinking civic spaces, traditional funding models are often peripheral to the flows that already sustain communities.
How philanthropy can adapt when systems designed to help start to fail
Funders shouldn’t necessarily draw the lesson that they should abandon caution (nor is that likely in a current operating environment of increased vigilance). Compliance and impact need to be thought about together, not sequentially. A fully compliant grant that never reaches those in need is not a success. Nor is it asking local partners to absorb the risk. The task is to find a workable balance.
The playbook for philanthropy in these contexts must be rewritten:
Understand the local operating environment before designing any intervention. That includes legal restrictions, banking realities, political sensitivities, and the informal networks that already move support
Fund the network, not the node: When organisations are banned, the network remains. Funders should support decentralised movements and individuals, not just formal entities. Direct funding to individuals is often the fastest way to move resources, but it is hard to scale and rarely builds lasting infrastructure. This creates a trade-off between speed and system-building that must be managed deliberately.
Treat local knowledge and diaspora networks as core infrastructure, not as informal add-ons. These actors already have the trust, reach, and adaptability. Philanthropic engagement with diaspora communities is not new. For example, the Open Society Foundations supported the Colombian government in developing policies that granted legal status and access to social services to more than 500,000 displaced Venezuelans.
Preserve social fabric, sustain basic capacities, and keep channels of solidarity open and diverse. Support community-level resilience rather than trying to replicate conventional civil society models.
In a closed space, ‘impact’ might simply mean an organisation surviving another year. Streamline reporting and invest in context-appropriate due diligence that enables funds to move safely and effectively.
Invest in ‘Financial bridges’: There is a desperate need for specialised intermediaries—legal and financial entities in third countries—that can navigate the compliance landscape. Accounts and entities based in third countries that sit outside both the US system and the domestic constraints of countries like Cuba or Venezuela. These arrangements are often informal, sometimes personal, and rarely come with the kind of historical financial data that funders rely on for due diligence, and funders must be comfortable with this. Independent media is normally savvy in surviving using these kinds of entities. And organisations like the Media Development Investment Fund have long played this role, structuring investments and funding flows that allow partners to operate across restrictive environments.
Accept that some of the most meaningful support will remain invisible. It is all about access, trust, and the ability to operate without causing harm.
For philanthropy, this means trading some control for relevance, visibility for discretion, and certainty for practical effectiveness. It also requires a more honest conversation about what success looks like in restricted environments.
In Cuba, as in other closed civic spaces, the right response is not to force familiar models onto an unfamiliar reality, but to adapt with humility.
Yery M García is Communication Officer at The Trust, Accountability and Inclusion Collaborative
Bryan M. Sims is Director of Peacebuilding and Partnerships at Humanity United
Michael Jarvis is Executive Director of the Trust, Accountability and Inclusion Collaborative.