On May 18, 2020, the Federal Maritime Commission (FMC) published its Final Interpretive Rule on Demurrage and Detention Under the Shipping Act (“Demurrage/Detention Rule”), 85 Fed. Reg. 29638, 29638 (May 18, 2020). This final rule, nearly six years in the making (as detailed in the Background section of the Final Rule), was the culmination of …