Tomorrow (30 September) is the last day to submit comments to National Treasury and SARB on the Draft Crypto Asset Manual. Please do. One point worth considering in your submission: The proposed Authorised CASP framework appears to be modeled on the existing ADLA framework used in foreign exchange. (CASP = Crypto Asset Service Provider & ADLA = Authorised Dealer with Limited Authority) But there is a critical difference. In FX, an ADLA sits below an Authorised Dealer (a bank with broader authority). If a transaction falls outside the ADLA’s mandate, a client can still go to a bank. There is no equivalent upper tier for crypto. No bank or crypto exchange or any other entity is being authorised under the draft manual to provide the crypto activity that an Authorised CASP is prohibited from providing. So a limitation that is relative in the FX system would become a prohibition in the crypto system. The result is that two businesses trying to facilitate economically equivalent cross-border payments would face very different regulatory outcomes purely because one uses conventional banking rails and the other uses crypto rails. The restriction attaches to the technology rather than the underlying risk or economic activity. In essence, this bans crypto assets from being used as a cheaper, faster, and more transparent payment mechanism by all South African businesses. This outcome is neither fair nor technology agnostic nor in the best interest of South Africa. New technology should be regulated appropriately. Regulation should focus on the economic activity and risks involved, and allow useful new technologies to compete... not prohibit them without a sound, risk-based justification. Please submit your comments by tomorrow. South Africa needs to get this right. [Repost for reach if you'd like to help]