True. The FAA requirement is three out of three at night, while JAR-FCL was one out of three. I have not checked the EASA requirements, but I'll take your word that it's one out of three as well.
EASA require 1 out of 3. That is all a pilot with an EASA qualification would need.
However someone relying on their FAA qualification(s) must have
valid FAA qualification(s). If the FAA require 3 out of 3 in order to be valid then, surely, that is what the pilot must have?