The navigation lights should be on. They are not immune to the ColRegs (but they can add more lights and dayshapes if they want as long as they don't add anything confusing).

I don't understand how, after three accidents, they don't have a policy of careful watch in an area like that. Something still doesn't smell right with the info we're getting.

My theory is this is a covert operation by the Chinese to disable the U.S. 7th Fleet, one merchant ship collision at a time. :)