Why are some EDGE_LOOPs in STEP files discontinuous?

I have recently begun working with STEP files and have found that for some faces, the EDGE_LOOP that constitutes the FACE_OUTER_BOUND or FACE_BOUND is discontinuous (By working backward through the ORIENTED_EDGEs, EDGE_CURVEs, VERTICEs and LINEs/CIRCLEs/B-splines, I traced the paths they formed). I was of the belief that the EDGE_LOOP uses ORIENTED_EDGEs and not EDGE_CURVEs themselves so that it can set the EDGE_CURVES in the correct orientation and hence, 1 continuous loop is formed.

If you are an expert in STEP, can you please clarify why some of these EDGE_LOOPs, although forming closed faces, are not strictly clockwise or anti-clockwise?