You hit the nail right on the head here. Sight seeing tours require an AOC nowadays. Which I do think is not correct. In Austria for example they have an exception for AOC requirement for sight-seeing tours. It's much safer to do a sight-seeing tours without dual controls then having to have the duals in and flying with a nitwit and 2 'family members' in the back.
But this has nothing to do with the original thread, of course, because it's flown by FI's