In an important case of first impression, the federal Fifth Circuit has just affirmed that contractors cannot be criminally prosecuted for violations of various safety regulations under the Outer Continental Shelf Lands Act (OCSLA). See United States v. Moss, No. 16-30561 (5th Cir. Sept. 27, 2017).  This decision has broad implications—both in the criminal

On June 9, 2017, the Bureau of Safety and Environmental Enforcement (BSEE) issued a final rule amending certain regulations in 30 CFR Part 250 to extend the time that an Outer Continental Shelf (OCS) lease remains in effect after cessation of production or other operations to one year.

Under the previous regulations, an OCS lease