Banggearo
I would suggest that it is not clear, is it not worth checking with the CAA to esnure that PART-FCL and the ANO is not going to be broken? Or has that already occurred? I would suggest that just denying it is not a defence because you thought it was alright!
Sorry to be a pain, but to me the ANO and the RA make your position unclear to me. A quick email or phone call to the SARG would clarify. As I say, I hope someone has already checked!
LJ