The currents at Penida are produced principally by the movement of ocean water called the Indonesian Throughflow, not by tidal forces (full moon or not). The Indonesian Throughflow, which transfers enormous quantities of water between the Indian and Pacific Oceans, carries tremendous energy. The amount of water moved by the ITF is so massive that it boggles the imagination--in fact, it is measured in units called sverdrups invented specifically to describe such huge water movements. One sverdrup is equal to one million cubic meters of water per second. The estimate of the amount of water that passes through the ITF is between 20 and 22 sverdrups--20 to 22 million cubic meters of water per second, every second of every day, regardless of the phase of the moon.
In addition, the Throughflow creates extremely complex ocean dynamics that involve salinity, water temperature, interactions between diurnal and semi-diurnal tides, and other forces. I have yet to meet any dive guide on Nusa Lembongan or Nusa Penida who claims to be able to predict the currents at Crystal Bay or at Blue Corner (which, IMO, is an even more dangerous dive) with much confidence. They will all tell you that the currents can come up in a flash, unexpectedly. The closest call I have ever had, personally, was in a downcurrent at Blue Corner.
While we do not know what the exact precipitating cause of this tragedy was, I again caution against laying blame on the diver, the dive guide or anyone else. There must have been some mistake made, but we cannot know what nor by whom at this point. Furthermore, culpability and responsibility are two different things. If this diver indeed had 70 dives to her credit, I can see no reason to say that the operator acted irresponsibly in allowing her to do the dive. This diver was not fresh off a course with little understanding of her own abilities. She chose to do the dive, as we all do when we don our gear and splash in. Personal responsibility is of prime importance. This is why I disagree with your assessment that the operator must take responsibility for this accident.