It seems there is a loophole that Ferrari is currently exploiting.... they have downforce making devices "to direct air to the radiators" within the sidepods. Since they are not visible they are legal.
A great conceptual coup over the regs in my opinion, but what is to stop a team from making a "second skin" car? Mercedes sort of started it last year with their internal monocoque and 'cartridge' system.
By second skin I mean a slightly larger covering over an internal covering used to "improve cooling" on a much larger scale.
To put the hole in the rules in perspective, the radiators themselves are internal aero devices the teams work to optimize, and what constitutes a radiator or a flange for the rad that improves cooling but also adds downforce?