Theme One: The Struggles Are Operational, Not Theoretical

In every room, the practitioners and policymakers I met were describing real, measurable friction. The stakes are precisely: roughly 5.8 million South African crypto holders, more than 300 licensed Crypto Asset Service Providers, billions in mostly offshore investment, and over R1 billion in annual tax revenue. That is what a decade of risk-based regulation has built, and it is what the next phase of policy is being asked to preserve.

Across the four engagements, the struggles cluster into five hard problems.

First, the supervisory perimeter is uneven. In Zimbabwe, large diaspora remittance flows still move through informal channels because formal options are too costly or too slow. In Nigeria, the IMF flagged this month that nearly 60% of sub-Saharan stablecoin inflows now go through that one market, with around 95% of crypto-active users preferring stablecoins over the naira. This is not unique to West Africa. Argentina and Venezuela show the identical pattern: when the local currency loses credibility, dollar-pegged stablecoins fill the gap, regardless of continent. Across the continent, mobile money has reached close to a billion wallets, and stablecoin usage in sub-Saharan Africa grew roughly 180% year-on-year per Chainalysis. The activity is real. The question is whether it sits inside a regulated and reportable system, or outside it.

Second, the legal foundation is unsettled. In South Africa, the Mangundhla v SARB ruling on 1 June declared Bitcoin to be "money" and "capital" under the 1961 Exchange Control Regulations, contradicting the Standard Bank ruling from 2025. Underlying both is a deeper question, anchored in the Oilwell precedent: whether the Currency and Exchanges Act of 1933 reaches "capital at large" or only exchange rates. This kind of unsettled legal foundation is not a South African quirk. US courts are still working through whether various digital assets are securities or commodities, and Indian courts have wrestled with near-identical questions of whether crypto counts as currency, property, or something else entirely under existing exchange control law. Until that is settled by the Supreme Court of Appeal or by Parliament, programmes designed under contested legal authority carry implementation risk for every operator and every customer in the chain.

Third, regulatory fragmentation is the operational tax. 54 African jurisdictions, each developing its own framework, with limited mutual recognition between them. From the compliance seat, a multi-jurisdiction operator faces compounding cost and complexity. This is the same fragmentation problem the European Union spent years solving through MiCA, and that Southeast Asia is now working through as Singapore, Hong Kong, and the UAE each build competing licensing regimes. The risk is not regulation itself; it is fragmentation without harmonisation.

Fourth, the Travel Rule interoperability gap is concrete. South Africa's Directive 9 and PCC 61 have brought the FATF Travel Rule fully into operational scope, that requires originator and beneficiary information transmitted simultaneously with every CASP-to-CASP transfer. The harder problem is that South African CASPs and banks have a documented compliance gap on cross-border messaging interoperability, and closing it requires industry-wide adoption of common protocols such as TRP, Sygna, and Notabene.

Fifth, displacement is the supervisory risk regulators rarely cost in. When friction on licensed platforms gets too heavy, customers and operators do not stop transacting. They move to peer-to-peer, offshore, and self-custody channels with less supervisory visibility, not more. Every transaction that moves off a licensed CASP is a transaction the supervisory perimeter loses.