These are excellent questions that you will have to have shown you've considered if you get audited. If there's disagreement with the regulator, you'll come together to resolve it, and then may need to appoint one.
Well, so it's undefined, at least until practice of legal application establishes. Undefined means risk, and stopping serving EU is a meaningful mitigation, if your profits don't compensate you for all the hassle. Where's "overreaction“ then?
