those who frequent flying clubs are likely to be aware of the lower level of safety regulation they enjoy.
That made me smile
Actually it's true only for some. It's not until one gets out of the school scene and becomes an owner that one realises how much dodgy maintenance goes on.
Frankly, the Internet has little relevance, clubs could have a website and if that's how they communicate with members then I doubt that any court would rule that unreasonable. The spirit of the rule is that you don't advertise in the public domain.
That's my take too i.e. the "club" can be virtual, but (and we have done this to death here already) that's not what the ANO suggests.
I think the objective is to prevent the carriage of paying passengers. The only way to stop it effectively is to make sure the pilot cannot make a profit out of it. So I doubt enforcement will take place against a scheme where the cost sharing maximum percentages are maintained. It is insurance that would worry me; an injured passenger has a big financial incentive to claim that the pilot breached the cost sharing rules. The possible fact that the passenger was a party to a crime (by knowingly going along with it) is fine; he will still get his insurance payout.