Yeah, but a PPL has never been much of a problem. Medical issues aside (and yes these will ground some pilots for ever) a PPL conversion is basically easy.
The big Q is whether anybody will convert an FAA IR into an EASA IR.
Englishal - I agree that ramp enforcement is going to be zero, because of the impossible "residence" test. It is insurance that would concern me. Insurers love grey areas which enable them to play... they can ignore them, until you stick a big claim in and then they pull it out.