It isn't clear if its illegal to use ones Single Discretionary allowance (SDA) (1m ZAR per annum) or applying for and using a Foreign investment allowance (FIA) (further 10m ZAR per annum) for crypto.

If exchange control was applied fairly as was the interpretation up until recently, then staying below those amounts in ZAR terms would be fine. However, that may not be the case any more.