421C,
I am struggling a bit on this operator stuff. HMRC on the GAR specifically require details on the operator and not the pilot (so the club, school, owner, is listed).
The ANO has a large number of technical requirements on the operator that are unlikely to be met by the average group pilot.
If I let someone fly my airplane I wouldn't expect to give them access to my aircraft logs for example. I accept that for a single beneficial owner, they are the operator, owner and pilot. However, in groups just because someone is flying the plane doesn't appear to make them the operator.
It would be even less logical if a corporate entity with directors handling separate aspects would be deemed to have each director be personally an operator rather than the corporate entity as the operator.
For someone like Pace (I assume flying some company's N-reg jet) it must either truly be an American controlled company or owned by an entity which could easily establish it's operating essence as a non EU based US Person.
I have struggled to find a very firm definition of what constitutes an operator (other than in The absence of an entity that acts as the manage, it is the pilot)
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On your example, I don't think anyone has suggested saying one is not a EU resident/citizen. However, they are saying the operator is not located in the EU (the operator being the owner, policy setter, etc who has rented the aircraft to the pilot).