The loophole isn’t “12 hour watches” getting time and a half. The loophole is the people getting screwed with only1 day of seatime for 12 hours on watch with 4 hours overtime under the traditional 3 watch system because verbage on the COI. Its a contradiction in terms. The Maritime Unions never stepped up to the plate on that one.
What does a trans-Atlantic voyage and South America have to do with being a Captain? Last I checked, you could be a good Captain in the North Pacific.