It's going to be one for the Exceptions Panel.
This the criteria (you need 4 points to qualify):
Criteria
The transfer fee paid for the player is above the 75th percentile of qualifying transfers. 3 pts
The transfer fee paid for the player is between the 50th and 75th percentile of...
. A club need to have applied for a permit prior to the window closing.
The UK Home Office has a points-based system based on which clubs must apply to The FA for a "Governing Body Endorsement" for such players. (See p551 of the Premier League Handbook 2018/19 (Download PDF, size: 8.39MB))
If...