You can't restrict access to the guard-systems, which aren't there anymore for the OC because they had been de-guarded to be used in lore, to properly ID'd and IFF'd ships.
You can't just bounty ships of your own NPC-ID without an FR issued first. The bounty on the 101st was put up days before the FR5 was executed, which is a rule-violation in itself.
Any FR2 usage is invalid as the method of getting said information, if any at all, violates other rules, namely the faction ones.