It seems there is an easy loophole.... Just declare the satellite mission to be super long. Eg. This spacecraft will act as a Comms satellite for 10 years and will then go into a low power mode where it switches to 'gamma ray burst detection mode' which will be active for 150 years, upon which it will then deorbit within 5 years as regulated.
1. Pretty easy to detect for most cases, especially as blunt in your (exaggerated, I know) example. Agencies should have a rough idea about realistic time frames for mission times in near earth orbits depending on what the satellite does.
2. They still need to have the propulsion unit integrated in the satellite, as otherwise they cannot guarantee the 5 years after mission time in higher orbits. They'll also need to prove that the propulsion unit used is very likely to actually work after mission time, e.g., your 160 year in radiation ridden space, which may be much more expensive than constructing one for the shorter, actual mission time.