Sure one can think of ways to get around it. For example any VP-reg jet owner (let's assume he is non EU resident) could fire his pilots, transfer the jet to EU-reg, and hire JAA CPL/IRs out of the well stocked ex airline pilot pool, etc.
More cheaply, he could stick with the VP- jet and fire just the EU-resident crew and replace them with Croatians living out of hotels, with no permanent address
IO,
I think you've misunderstood the Basic Regulation. It says that an
Operator residing in the EU must abide by the EASA regs. But there is nothing to stop an Operator outside the EU using crew within the EU who reside in the EU. For example, an Asian airline may have crew who live in the UK. They do not need EASA FCL licences - just the licences of the state of registry.
The problem is for FRA operators residing in the EU...
brgds
421C