Global Digital Finance (GDF) has submitted a response to the South African Reserve Bank (SARB) Financial Surveillance Department’s consultation on its Draft Crypto Asset Manual for cross-border activities, which sets out the conditions under which authorised crypto asset service providers (CASPs) may conduct cross-border activity, including remittances, together with related approval, capital, reporting and operational requirements.
GDF welcomes SARB’s objective of bringing cross-border crypto-asset activity within a lawful, transparent and supervised framework. However, the response notes that the Draft Manual is not yet implementation-ready: the related Capital Flow Management Regulations remain under review, and core reporting categories, technical specifications and the Operations Manual would only follow after the policy framework is adopted, leaving firms unable to assess the full legal, operational and cost impact.
The response sets out 13 recommendations. Key themes include adopting a functional, risk-based taxonomy that distinguishes payment stablecoins and tokenised regulated assets from unbacked crypto assets; providing a clear route for regulated interoperability between banks and CASPs and protecting legally enforceable issuer redemption rights; basing cross-border classification on residence, ownership and actual destination rather than wallet type; permitting legitimate corporate, trade and CASP operational use cases; and calibrating remittance limits, capital requirements and customer evidence to risk.
GDF also calls for coordinated authorisation across FinSurv, the FSCA and the FIC, risk-based rules for cloud, data and global operating models, outcomes-based recognition of comparable overseas regimes, and a single API-first reporting platform aligned with international Travel Rule standards such as IVMS101.
Overall, GDF supports a regulated pathway for cross-border crypto-asset activity in South Africa, but recommends replacing blanket prohibitions with proportionate, activity-based and technology-neutral controls, publishing the full legal and technical package for consultation and testing, and providing a transition period of at least 12 months.
Date:
September 2026