Nope. Flying the Red Ensign? Legit target in 10/39. You don't want to waste an eto/ato on them, but the one or two 88mm rounds it takes are a valid expenditure.
They're either picquet boats or pleasure cruisers, and the only people who can afford to pleasure cruise in 1940s England, typically speaking, are the upper classes... and I just read Das Kapital for ****s und giggles. 
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Winter Garden on the North Atlantic
Currently: U128 (Type IXC), U180 (Type IXD2), U198 (Type IXD2) operating in the I.O.
Previously: U48 (Type VIIB), U568 (Type VIIC) [Completed 1940-1945 career in Type VIIs, in the Atlantic]
Running: SH3 v1.4b w/ GWX 2.1
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