Comment by rsync

"There's personal liability attached to being the named senior manager ..."

Thank you - that's a missing piece that helps.

"In addition to the "you're not fooling anyone" bit ..."

I don't suggest a corporate veil as a ruse - it's a tool that has a function and I think this is certainly it.

My sense is that enforcement for small operators is unlikely but the potential liabilities skew the risk dramatically. Pointing the initial enforcement at a corporate entity could change that risk assessment.