Control reversal speed is way lower than divergence speed. It may actually be lower than operating speed for some aircraft, which is why they have inboard ailerons/flapperonsflaperons and/or use spoilers (that don't suffer control reversal) for roll control at high speeds.
Control reversal (at high speed; there is also control reversal at stall, which is different) occurs because the force generated by ailerons twists the wing sufficiently so that the aileron starts to act more like a trim tab. For that the wing has to flex, but it does not have to flutter at all.
Spoilers act closer to the wing mid-chord, so they don't twist it much and thus don't suffer reversal. In fact they twist the wing a bit, because pre-stall lift acts more forward than post-stall lift, but this twists the wing forward and thus further reduces the lift, so still no control reversal.