U.S. Customs and Border Protection issued a ruling on May 30, 2014 regarding the application of U.S. towing laws to the movement of a mobile offshore drilling unit or MODU from a foreign shipyard to U.S. waters. U.S. towing laws require, among other things, that a qualified U.S. flag towing vessel be utilized for the towing of any vessel between ports or places in the United States “either directly or via a foreign port or place.” In the ruling, CBP indicated that the law would be violated if the MODU was towed by a foreign vessel from a foreign shipyard to a U.S. port even if the towing ceased outside U.S. waters because the MODU had first travelled to the foreign shipyard from a U.S. port.

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