We are dealing with media reports here so nothing is certain. However it is possible that the level of negligence passes the threshold into criminal acts. Responsibility for those criminal acts could include individuals/companies involved in making the arrangements if they knowingly hired a pilot without the necessary qualifications, or even worse, hired a pilot who would pretend to be someone else to use their qualifications. Note, I have said IF, because nothing is known for certain at this stage.
I have to say that I am absolutely astonished that the Cardiff Manager has admitted to being flown by the pilot. I’d like to know the circumstances of that flight.