Yes! That's exactly what I mean. If they banned by version, all Pokemon Sun AND moon carts (and CIAs that came from the carts) would be instantly banned.
This is not the case since the game has been released NA/AUS/JP.
However, connect online in the regions considered as "Europe" before the 23rd and you will be banned.
I live in South American, my 3ds is considered USA(well, it IS USA) and the eshop/freeshop is already avaliable in my country to buy/download, so can I already play online?