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Displaying the 15 latest comments.
Submitted | first-name | support | concern | top-concern | message |
|---|---|---|---|---|---|
2026-09-17 13:37:28 +02:00 | Peter | No I do not | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) | ||
2026-09-17 13:36:35 +02:00 | Phemba | No I do not | Threat to Domestic Fintech Jobs, Foreign Investment & Tax Revenue | ||
2026-09-17 13:36:34 +02:00 | Leon | No I do not | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) | ||
2026-09-17 13:36:02 +02:00 | Corne | No I do not | The Inward Self-Custody Trap (Banning transfers from non-custodial wallets) | ||
2026-09-17 13:35:27 +02:00 | Tertia | No I do not | All of the above | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) | |
2026-09-17 13:35:25 +02:00 | Hermanus Hercules | No I do not | All of the above | The Blanket Prohibition on Corporate/Business Cross-Border Payments | |
2026-09-17 13:33:47 +02:00 | Shaun | No I do not | The Inward Self-Custody Trap (Banning transfers from non-custodial wallets) | 1) It seems bizarre that once money leaves it cant come back into rands. 2) This seems to be counter productive as it closes down a lot of business in the fintech space. 3) It would make more sense to regulate it properly so people can comply rather than force it underground. We can see the impact that cigarette ban had and the devastation on local industry. It makes more sense to be more open but regulate strictly in a way that applies policy equally across all monetary and technology forms so that it can be monitored and controlled using the public ledger rather than forcing this to be hidden. 4) The Inward Self-Custody Trap (Banning Non-Custodial Wallet Transfers) Objection: Forcing incoming funds through centralized intermediaries restricts user asset sovereignty and punishes legitimate self-custody practices. Alternative: Implement a risk-based approach utilizing on-chain analytics and address ownership verification tools to verify non-custodial deposits without outright bans. 5) Blanket Prohibition on Corporate/Business Cross-Border Payments Objection: Blocking local businesses from cross-border crypto transactions severely hinders trade efficiency, international competitiveness, and modern supply chain operations. Alternative: Permit authorized corporate entities to conduct cross-border crypto transactions subject to standard corporate foreign exchange reporting, compliance limits, and tax auditing. 6) Discrimination Against Technology Objection: Treating digital assets more restrictively than legacy fiat banking models violates the principles of technology-neutral regulation. Alternative: Standardize cross-border regulation so compliance, AML, and reporting obligations apply equally based on transaction size and risk level, regardless of whether fiat or blockchain technology is used. 7) Threat to Domestic Fintech Jobs, Foreign Investment & Tax Revenue Objection: Over-regulation risks driving capital, Web3 talent, and tech ventures out of South Africa to more competitive, crypto-friendly jurisdictions. Alternative: Introduce regulatory sandboxes, clear compliance pathways, and growth-friendly operational tiers to retain local innovation, attract foreign investment, and collect domestic tax revenues. 8) Anti-Competitive CASP Capital Barriers (R5 Million Locked Fiat Mandate) Objection: A flat R5 million locked capital requirement creates a massive barrier to entry, stifling startups while consolidating market dominance among legacy institutions. Alternative: Replace the flat R5 million lock-up with a tiered, activity-based capital requirement system indexed to a platform's transaction volume, risk exposure, and assets under custody. 9) Administrative Disorder (Unsettled Parent Regulations) Objection: Issuing an operational manual before the overarching legal and parent Capital Flow Management Regulations are finalized creates procedural unfairness and legal uncertainty. Alternative: Pause the implementation of operational manuals until the parent legislative framework is fully gazetted and finalized after comprehensive stakeholder consultation. 10) Privacy Overreach & Permanent Ledger Tracking Objection: Blanket, permanent public ledger transaction tracking risks violating constitutional rights to privacy under Section 14 and POPIA regulations. Alternative: Enforce targeted, warrant-based data access and privacy-preserving compliance tools (such as zero-knowledge proofs) that protect user privacy while allowing targeted law enforcement oversight. 11) Exclusion of the Common Monetary Area (CMA) & Low Remittance Limits Objection: Severely limiting cross-border remittances and excluding neighbouring CMA countries damages regional economic integration and penalizes migrant workers sending low-value support home. Alternative: Establish a streamlined, low-value remittance corridor across CMA member states with higher transaction thresholds and reduced compliance requirements for personal transfers. | |
2026-09-17 13:32:23 +02:00 | Ingo | No I do not | All of the above | The Inward Self-Custody Trap (Banning transfers from non-custodial wallets) | |
2026-09-17 13:32:13 +02:00 | Theron | Not fully | The Inward Self-Custody Trap (Banning transfers from non-custodial wallets) | I do not support the Draft Crypto Asset Manual in its current form, specifically regarding its treatment of non-custodial/self-custody wallets. I support appropriate regulation of crypto assets and recognise SARB's legitimate responsibility to monitor cross-border capital flows and to prevent money laundering . However, I am concerned that treating the transfer of legitimately acquired crypto assets from a South African authorised CASP to a person's own non-custodial wallet as a cross-border transaction, while apparently restricting the subsequent transfer back to a South African authorised CASP, creates an unnecessary and potentially one-way restriction on legitimate ownership and use of crypto assets. A South African resident should be able to purchase crypto legitimately through a regulated South African provider, take self-custody of that asset, and subsequently return it to the regulated South African financial system for sale or conversion into Rand. If the concern is that self-custody can be used to move capital offshore, this should be addressed through proportionate reporting, source-of-funds requirements and transaction monitoring rather than effectively treating self-custody itself as an outward cross-border transaction. I therefore request that SARB reconsider the proposed treatment of non-custodial wallets and provide a clear, practical mechanism allowing legitimately acquired crypto assets to be returned to a South African authorised CASP and converted into Rand. | |
2026-09-17 13:29:17 +02:00 | Shrian | No I do not | All of the above | Discrimination Against Technology (Breach of Governor Kganyago's Principle) | |
2026-09-17 13:28:41 +02:00 | Saroj | No I do not | All of the above | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) | |
2026-09-17 13:28:04 +02:00 | Adila | No I do not | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) | If the State can decide that holding your own property in private custody makes it "non-permissible" to repatriate, what stops them from applying the same logic to other private assets in the future | |
2026-09-17 13:27:14 +02:00 | Michelle | No I do not | All of the above | The Blanket Prohibition on Corporate/Business Cross-Border Payments | |
2026-09-17 13:26:27 +02:00 | Lawrence | No I do not | All of the above | The Inward Self-Custody Trap (Banning transfers from non-custodial wallets) | What is yours is yours, and what is mine is mine. That is the principle. Anything else is theft! |
2026-09-17 13:26:16 +02:00 | Ignitia | No I do not | All of the above | Privacy Overreach & Permanent Ledger Tracking (POPIA / Section 14) |
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- Curbing Regulatory Arbitrage:
Unregulated cross-border crypto movements undermine the foreign exchange framework. Bringing crypto transactions within standard balance-of-payments reporting ensures that fintech entities face the same compliance oversight as commercial banks. - Defending the Fiscus & National Currency:
In an era of borderless digital finance, untracked capital outflows threaten domestic macroeconomic stability and the South African Rand. Comprehensive surveillance enables FinSurv to track the true volume of capital moving across borders. - Protecting International Financial Standing:
Following South Africa’s removal from the Financial Action Task Force (FATF) grey list, closing cross-border anti-money laundering and counter-terrorist financing (AML/CFT) loopholes is necessary to maintain global banking relationships. - Ensuring Platform Solvency:
Enforcing a minimum unimpaired capital reserve of R5 million and mandating client asset segregation protects everyday consumers from exchange collapses and fraudulent practices. - Structured Industry Pathways:
The manual replaces legal ambiguity with a defined, tiered licensing model (Category 1, 2, and 3), providing institutional legitimacy for compliant operators.
- Curbing Regulatory Arbitrage:
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- Breach of Technology Neutrality:
SARB Governor Lesetja Kganyago stated that “similar payment activities should be subject to similar regulatory expectations, whether they are performed by a bank or a fintech.” The draft manual breaches this principle by permitting businesses to execute international vendor settlements via SWIFT while outright banning the exact same economic transaction if routed through regulated blockchain rails. - The “Cold Storage Trap”:
Classifying inward transfers from non-custodial wallets as non-permissible penalizes the foundational property of public blockchain technology: individual self-custody. It creates a one-way street where citizens can take custody of their digital property, but are legally locked out of the domestic banking system if they ever wish to repatriate it. - Economic Isolation of South African Enterprise:
Banning South African companies and trusts from cross-border crypto rails isolates the domestic tech sector, digital exporters, and Web3 startups from the global digital economy, preventing them from using efficient stablecoin settlement channels. - Threat to Domestic Jobs & Foreign Investment:
The industry-led CATASTROPHE coalition (including VALR, Luno, AltCoinTrader, and EasyEquities) warns that billions of Rands in foreign direct investment into South African fintech have been frozen, putting thousands of skilled jobs and significant corporate and PAYE tax contributions at immediate risk. - Perverse Incentive for Unregulated Flight:
Imposing non-workable restrictions will not stop digital asset usage; it will simply drive liquidity away from compliant domestic exchanges into unregulated offshore peer-to-peer (P2P) networks, blinding both FinSurv and SARS. - Administrative Cart Before the Horse:
Requesting public commentary on operational directives while the parent Capital Flow Management Regulations remain unresolved undermines procedural fairness under PAJA.
- Breach of Technology Neutrality: