Just when you thought it might get easier.
Let's forget for a moment FCL. If an N reg aircraft, which has to be owned by a UStrust, operating in EASA land, but for all intents is a US owned and operated aeroplane, then to me the trust is the owner/ operator. Unless otherwise stated. All insurance companies currently accept this. No issues then?
If the pilot has both a current EASA licence, and an FAA current licence, then he is legally able to fly the aeroplane?
MJ - exactly who are 'they'. Your scenario conjures up scenes of official checkers hiding behind hedges on the look out for third country reg planes, ready to pounce with a full file of 'new' EASA dic tats.
If most on here cannot fully understand, nor decipher, forthcoming, proposed rules and regs, and that includes the relevant authorities themselves, then sorry, I also just do not see it.