I have been doing FAA IR training here in the UK for a while now and have been in contact with both the DfT and the CAA. I have found them most helpfull in making sure both my clients and myself stay within the law. I think the DfT are looking more at the operations of N-reg jets etc who are running charter operations than the GA owner/operator. I think the issue is more about persons contravening Articles 29 and 115 than closing down people who want to get a FAA IR and keep their aircaft on the N-reg. This would apply also to people who are unable to get a class 2 JAA medical, but can make the FAA class 3.
As I've said, I've made sure I've complied with both the DfT requirements and also operate in strict accordance with the CAA regulations under the priveleges of my CAA ATPL and Instructors ratings and if I am in doubt I contact the CAA/DfT for clarification. I feel quite confident and comfortable with the way I operate and so do my clients who know I make sure we are both operating within the law. If someone feels inclined to prosecute me they will be hard pushed to suceed with the evidence of previous consultation I have had with the relevant departments.
