The original question did get me thinking about how EASA are promulgating this requirement apart from word of mouth to the Pilots who will be affected.
My understanding is that it has been largely left to the competent authorities in each Member State to promulgate the requirements. Certainly the UK CAA has published quite a lot of information on the subject. I also understand that the Cayman, Bermudan and Manx authorities are aware of the issue and advised the owners of aircraft on their registers. The FAA also appears to be well aware of the issue and I would be surprised if they had not promulgated the information in some way.
Neither the basic regulation nor part FCL restrict the geographical scope of the operation.
The applicability of the basic Regulation is set out in Article 4. The paragraph relevant in this case is paragraph 1(c). This states that the Regualtion applies to aircraft "registered in a third country and used by an operator for which any Member State ensures oversight of operations [ie an EU AOC holder]
or used into, within or out of the Community by an operator established or residing in the Community" Compare this to paragraph 1(b) which states that the Regualtion applies to aircraft "registered in a Member State, unless their regulatory safety oversight has been delegated to a third country and they are not used by a Community operator". So the Regulation applies to EU registered aircraft and aircraft registered in a third country which are operated by an EU AOC holder where ever the aircraft are operated. However, privately operated third country registered aircraft operated by EU residents are only caught when used into, within or out of the Community. There is nothing in the applicability provisions that extend to scope to the private operation of third country aircraft outside of the EU.
Part FCL allegedly applies to operations of aircraft.
The Aircrew Regulation (1178/2011) does not mention operators. The requirements are set out in terms of pilots. However, the applicability of the requirements is by reference to Aticle 4.1(b) and (c) of the Basic Regulation so the operator of the aircraft is very relevant in the case of aircraft registered in a third country.
It would be career risking for a local CAA official to start a witch hunt without rock solid political backing from their transport minister.
The Member States voted (unanimously I am told) in favour of both the EASA Regulation and the Aircrew Regualtion. Member States are also under a legal obligation to enforce EU legislation. I therefore do not see why it should be career risking for CAA officials to enforce the law. Indeed they will place themselves in a very difficult position if the ignore evidence of illegal activity. If in subsequent legal action the courts find that the law is leaglly defective I do not see why this should have any adverse consequences for the authority taking the legal action. Rather it will be a problem for the EU Commission which is responsible for the legislation.