There is a possible loophole in the PVSA that nobody has discussed. The act itself is clear enough outlining what you can and can't do and who can and can't do what, but if you look at the penalties you can see the clearly preset dollar amounts per passenger. Now if you dig a little farther you will see that the U.S. Customs and Border Protection agency are responsible for setting these monetary amounts and have every right and ability to reduce or suspend the monetary penalties. So in theory if advised by the CBP that all penalties related to the PVSA would be waived, a cruise operator could knowingly violate the PVSA and not have to be penalized. It's a stretch, but there is leeway in the act as written to have the scenario happen.