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You keep saying this, but the question specifically addressed US boats in US waters running a US licensed operator. What heppens in the rest of the world, for better or worse, is better or worse. I know of operations in Grand Cayman who don't use a licensed individual at all. But that isn't the question. And the OP didn't ask if you had a problem with it, he asked if PADI had a problem with it. My guess is that PADI doesn't address it. PADIs insurance company would say "The boat must be operated in accordance with all applicable regulations". The Coast Guard would float an air biscuit and start an investigation, no doubt. The operator would tell the CG it was OK, no current, holding a line, etc. He would then get his pee-pee whacked and his birthday taken away for a period not to exceed 5 years.It comes down to probability and at what level of risk a boat op (and clients) are willing to take.
I can't find a regulation because I'm sure it doesn't even cross anyone's mind that anyone would actually do this. In fact, an operator in Key West routinely did this, and the investigations office couldn't catch him at it. Until they did......