I can’t give you definitive answers about what will or won’t pass App Review; only App Review can do that.
At a technical level, my experience is that doing ‘clever’ things with APIs — that is, using them for purposes which they weren’t originally designed for — is generally not a good idea. APIs and their implementations tends to evolve over time; this evolution is guided by the intended uses of the API and thus doesn’t take into account your ‘clever’ misuse.
If you’d post more details about what you’re doing, I can offer a more specific technical opinion.
Finally, on a personal note, if I installed an app and it unexpected asked for VPN privileges, I’d immediately uninstall it.
Share and Enjoy
—
Quinn “The Eskimo!”
Apple Developer Relations, Developer Technical Support, Core OS/Hardware
let myEmail = "eskimo" + "1" + "@apple.com"