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Oil and Gas Regulatory Consulting

    • Learn more about Oil and Gas Regulatory Consulting
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    +1 800 752 8878
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    +18007528878
    • Achieve worldwide energy regulatory compliance or attract international energy investment

    As oil and gas companies and government agencies adapt to evolving global energy markets, effective regulatory compliance management and attraction of international investments are mission critical. Corporate managers must ensure that they are complying with complex oil and gas regulations in multiple jurisdictions and adhering to industry best practices in order to minimize risks, reduce costs and avoid disruption. Government officials seek to attract energy investment while protecting national interests, safeguarding communities and environmental resources from potential risks.

    The upstream oil and gas regulatory consulting team at S&P Global can help you attract international investments into the energy sector as well as manage legal and regulatory compliance challenges and transform them into opportunities for progress – especially during capital intensive development and production phases. Our lawyers, regulatory specialists, ITC experts, information managers and other experts have deep experience working with leaders from industry and government around the world. We provide:

    • Country energy policy and master plan development – Understand best practices when opening up sectors and get assistance in the strategic steps forward.
    • Licensing-round strategy development, advisory and execution support – Predict bid round results and analyze bids received from energy companies to better negotiate from a position of strength and knowledge.
    • Fiscal and regulatory benchmarking and advice – Compare assessments and in-depth analysis of oil and gas fiscal systems and regimes against peer groups or develop composite indexes comparing fiscal systems to measure profitability, revenue risk and stability.
    • Drafting laws, regulations, standards – Explore the legal framework when developing legislation and regulations to encourage investment and development strategies, as well as strengthen regulation competencies that comply with international best practices.
    • Regulatory compliance support – Develop, maintain and populate an enterprise compliance solution for country or worldwide operations and gain a competitive advantage; access immediate answers to regulatory questions, reduce risk and manage information throughout the life-cycle of a petroleum investment. Download the Compliance Management Solutions Brochure.
    • Dispute Resolution Support – Deliver independent and credible expert witness and arbitration support services; understand what issues are relevant to the case and how they can be best presented; serve as independent experts or assist in formulating strategy, developing analysis and data during the entire discovery and trial process. Download the Dispute Resolution Support brochure.

    Visit Upstream Oil & Gas Consulting

    Dispute Resolution Support

    Read how we support you in managing regulatory risks

    Achieve worldwide regulatory compliance and attract international investment

    Improve strategic and tactical decisions
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    Services

    Companies

    The energy industry is highly regulated in many countries around the world. International oil companies, national oil companies, service companies and other energy firms need to understand how government laws, regulations and industry standards apply to their operations. Then they need to establish cost-effective processes to fulfill legal requirements throughout the lifecycle of their operations.


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    S&P Global regulatory experts can help you establish a best-practice compliance management approach that is tailored to your company so you can not only minimize regulatory risk but also gain an advantage over competitors by boosting operational efficiency and reducing costs.

    Our upstream oil and gas regulatory consulting team provides:

    • Legal applicability determination
    • Regulatory risk management systems
    • Advocacy and litigation support
    • Due diligence support
    Governments

    Government leaders around the world typically welcome investment by the energy industry. Oil and gas regulatory authorities want to encourage foreign companies to establish exploration and production operations in their country by offering a regulatory environment that allows the companies to earn strong ROI while also generating a reasonable revenue stream to the government and protecting their constituents’ interests.


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    S&P Global oil and gas regulatory experts can help you develop a winning strategy to attract E&P investment from major energy companies by ensuring that your regulatory framework is aligned with global best practices and therefore highly competitive with other countries seeking investors.

    Our upstream oil and gas consulting team provides:

    • Energy policy development
    • Assistance drafting laws, regulations, standards
    • Fiscal benchmarking
    • Licensing round support
    • National Data Repository
    • Organizational change management
    • Staff training/capacity building

    Experts

    Irena Agalliu

    Irena is an expert in international energy law and economics, worldwide fiscal arrangements, commercial risk and aboveground risk investment-related issues. She has extensive experience assessing commercial and regulatory risk and advising governments and NOCs on regulatory and contractual developments that impact E&P activities worldwide and assisting governments in formulating policies.Irena's major projects include assistance to the government of Mexico in development of industrial safety regulations for upstream oil and gas activities; assistance to the government of Colombia in development of offshore regulations, as well as development of fiscal and contractual framework for shale gas, tight oil and CBM; assistance to the legislature of North Dakota regarding fiscal policy solutions to enable CO2 EOR projects in the Bakken; assistance to the government of Angola on development of E&P regulations, LNG taxation and gas market regulations; and comparative analysis of fiscal systems for the United States Department of the Interior.Irena has provided independent expert review of proposed legislation governing petroleum upstream, midstream and downstream activities, revenue management in oil and gas, as well as local content participation, before legislatures of several African nations.Irena holds an LLM with distinction in Petroleum Law Policy and Economics from the University of Dundee, Scotland and a doctorate of jurisprudence from the University of Houston Law Center. She is a member of the State Bar of Texas and Association of International Petroleum Negotiators (AIPN). Irena was elected to the Board of AIPN in 2008 and served as vice president of external affairs for the 2009-2011 term and vice president of planning for the 2011-2012 term. She is the co-chair of the AIPN Oil and Gas Asset Valuation Workshop.

    View Profile

    Jim Thomas

    Jim is Executive Director of the S&P Global Commodity Insights Regulatory Compliance Consulting Group, with over 30 years of experience in environmental and regulatory management in the energy sector. Prior to joining S&P Global in 1999, Jim was a Senior Consultant with Petroconsultants, an Environmental Manager with Atkins Environment, a secondee to the UK Environment Agency and a Geochemical Analyst with BP. Within S&P Global, he has been responsible for the establishment and development of the regulatory consulting service, working on behalf of governments, national and international oil companies in over 40 different countries. Along with managing a team of legal and regulatory experts, he has been directly responsible for a wide range of different type of consulting services and assignments, each typically aimed at establishing best operational practices for governmental and non-governmental clients. The range of regulatory projects carried out includes compliance management system development, policy development, legal review and permit auditing, drafting petroleum legislation and H&S guidelines, fiscal benchmarking and analysis, negotiation support, licensing round management, technical due diligence and transaction support, organizational change and client training. The range of experience offered combined with consulting team expertise means that the Regulatory Group is well-placed to assist clients in making strategic and capital-intensive investment decisions.Jim holds a B.Sc. (Hons) Geology Decree (University of Leeds, UK) and a Ph.D. in Organic Geochemistry (University of Bristol, UK). He is a Fellow of the Geological Society and a member of the AIPN.

    View Profile

    Shawn Gallagher

    Shawn is an Associate Director in S&P Global Commodity Insights's regulatory group. She brings 18 years of experience in the oil and gas industry. She has advised governments and companies on a variety of topics including development of petroleum environmental and safety regulations, company analysis, unconventional oil and gas developments, and commercial, fiscal and economic terms. Previously, Shawn developed and managed the S&P Global Commodity Insights Herold Global Projects database, which tracked financial and operating details of significant upstream oil and gas development projects. Prior to joining S&P Global Commodity Insights, she worked in government and media relations for the National Petrochemical & Refining Association (NPRA) where she handled media requests, oversaw the website development and content, and tracked federal energy and environmental legislation and regulations relevant to the downstream sector.Shawn is a member of the State Bar of Texas. She has a B.A. from American University in Washington, DC, an M.B.A. from Thunderbird School of Global Management, and a J.D. from South Texas College of Law.

    View Profile

    Benjamin Morel

    Mr. Morel manages and contributes to a range of upstream energy regulatory consulting projects. His focus is on providing insight and analysis on energy regulatory systems across multiple jurisdictions globally. His team's clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments. Specific areas of expertise include providing regulatory research and insight on investment operations and fiscal systems, advising on energy contracts and rights allocation systems, drafting regulatory documents, litigation support and advising on practical compliance management at the project level. Mr. Morel's background is in commercial law and he holds a LLB (hons) from the Victoria University of Wellington, New Zealand where he focussed on the field of natural resources law and international environmental regulation. He also holds a Bachelor of Arts from the same institution and has been admitted as a barrister and solicitor of the High Court of New Zealand.

    View Profile

    Yelena Shliomenzon

    Yelena specializes in energy policy, legislation, and regulations, with particular emphasis on energy transition, technical, environmental, fiscal, contractual and permitting requirements, regulatory compliance and assurance management practices, regulatory risk management, stakeholders' engagement strategies, bid rounds and host government contracts.She is involved in designing and drafting energy, environmental, energy transition and petroleum policies, laws and regulations, upstream petroleum agreements, terms of reference for licensing rounds, litigation support and advising on practical compliance management at the project level.Her clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments.

    View Profile

    Irena Agalliu

    Irena is an expert in international energy law and economics, worldwide fiscal arrangements, commercial risk and aboveground risk investment-related issues. She has extensive experience assessing commercial and regulatory risk and advising governments and NOCs on regulatory and contractual developments that impact E&P activities worldwide and assisting governments in formulating policies.Irena's major projects include assistance to the government of Mexico in development of industrial safety regulations for upstream oil and gas activities; assistance to the government of Colombia in development of offshore regulations, as well as development of fiscal and contractual framework for shale gas, tight oil and CBM; assistance to the legislature of North Dakota regarding fiscal policy solutions to enable CO2 EOR projects in the Bakken; assistance to the government of Angola on development of E&P regulations, LNG taxation and gas market regulations; and comparative analysis of fiscal systems for the United States Department of the Interior.Irena has provided independent expert review of proposed legislation governing petroleum upstream, midstream and downstream activities, revenue management in oil and gas, as well as local content participation, before legislatures of several African nations.Irena holds an LLM with distinction in Petroleum Law Policy and Economics from the University of Dundee, Scotland and a doctorate of jurisprudence from the University of Houston Law Center. She is a member of the State Bar of Texas and Association of International Petroleum Negotiators (AIPN). Irena was elected to the Board of AIPN in 2008 and served as vice president of external affairs for the 2009-2011 term and vice president of planning for the 2011-2012 term. She is the co-chair of the AIPN Oil and Gas Asset Valuation Workshop.

    View Profile

    Jim Thomas

    Jim is Executive Director of the S&P Global Commodity Insights Regulatory Compliance Consulting Group, with over 30 years of experience in environmental and regulatory management in the energy sector. Prior to joining S&P Global in 1999, Jim was a Senior Consultant with Petroconsultants, an Environmental Manager with Atkins Environment, a secondee to the UK Environment Agency and a Geochemical Analyst with BP. Within S&P Global, he has been responsible for the establishment and development of the regulatory consulting service, working on behalf of governments, national and international oil companies in over 40 different countries. Along with managing a team of legal and regulatory experts, he has been directly responsible for a wide range of different type of consulting services and assignments, each typically aimed at establishing best operational practices for governmental and non-governmental clients. The range of regulatory projects carried out includes compliance management system development, policy development, legal review and permit auditing, drafting petroleum legislation and H&S guidelines, fiscal benchmarking and analysis, negotiation support, licensing round management, technical due diligence and transaction support, organizational change and client training. The range of experience offered combined with consulting team expertise means that the Regulatory Group is well-placed to assist clients in making strategic and capital-intensive investment decisions.Jim holds a B.Sc. (Hons) Geology Decree (University of Leeds, UK) and a Ph.D. in Organic Geochemistry (University of Bristol, UK). He is a Fellow of the Geological Society and a member of the AIPN.

    View Profile

    Shawn Gallagher

    Shawn is an Associate Director in S&P Global Commodity Insights's regulatory group. She brings 18 years of experience in the oil and gas industry. She has advised governments and companies on a variety of topics including development of petroleum environmental and safety regulations, company analysis, unconventional oil and gas developments, and commercial, fiscal and economic terms. Previously, Shawn developed and managed the S&P Global Commodity Insights Herold Global Projects database, which tracked financial and operating details of significant upstream oil and gas development projects. Prior to joining S&P Global Commodity Insights, she worked in government and media relations for the National Petrochemical & Refining Association (NPRA) where she handled media requests, oversaw the website development and content, and tracked federal energy and environmental legislation and regulations relevant to the downstream sector.Shawn is a member of the State Bar of Texas. She has a B.A. from American University in Washington, DC, an M.B.A. from Thunderbird School of Global Management, and a J.D. from South Texas College of Law.

    View Profile

    Benjamin Morel

    Mr. Morel manages and contributes to a range of upstream energy regulatory consulting projects. His focus is on providing insight and analysis on energy regulatory systems across multiple jurisdictions globally. His team's clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments. Specific areas of expertise include providing regulatory research and insight on investment operations and fiscal systems, advising on energy contracts and rights allocation systems, drafting regulatory documents, litigation support and advising on practical compliance management at the project level. Mr. Morel's background is in commercial law and he holds a LLB (hons) from the Victoria University of Wellington, New Zealand where he focussed on the field of natural resources law and international environmental regulation. He also holds a Bachelor of Arts from the same institution and has been admitted as a barrister and solicitor of the High Court of New Zealand.

    View Profile

    Yelena Shliomenzon

    Yelena specializes in energy policy, legislation, and regulations, with particular emphasis on energy transition, technical, environmental, fiscal, contractual and permitting requirements, regulatory compliance and assurance management practices, regulatory risk management, stakeholders' engagement strategies, bid rounds and host government contracts.She is involved in designing and drafting energy, environmental, energy transition and petroleum policies, laws and regulations, upstream petroleum agreements, terms of reference for licensing rounds, litigation support and advising on practical compliance management at the project level.Her clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments.

    View Profile

    Irena Agalliu

    Irena is an expert in international energy law and economics, worldwide fiscal arrangements, commercial risk and aboveground risk investment-related issues. She has extensive experience assessing commercial and regulatory risk and advising governments and NOCs on regulatory and contractual developments that impact E&P activities worldwide and assisting governments in formulating policies.Irena's major projects include assistance to the government of Mexico in development of industrial safety regulations for upstream oil and gas activities; assistance to the government of Colombia in development of offshore regulations, as well as development of fiscal and contractual framework for shale gas, tight oil and CBM; assistance to the legislature of North Dakota regarding fiscal policy solutions to enable CO2 EOR projects in the Bakken; assistance to the government of Angola on development of E&P regulations, LNG taxation and gas market regulations; and comparative analysis of fiscal systems for the United States Department of the Interior.Irena has provided independent expert review of proposed legislation governing petroleum upstream, midstream and downstream activities, revenue management in oil and gas, as well as local content participation, before legislatures of several African nations.Irena holds an LLM with distinction in Petroleum Law Policy and Economics from the University of Dundee, Scotland and a doctorate of jurisprudence from the University of Houston Law Center. She is a member of the State Bar of Texas and Association of International Petroleum Negotiators (AIPN). Irena was elected to the Board of AIPN in 2008 and served as vice president of external affairs for the 2009-2011 term and vice president of planning for the 2011-2012 term. She is the co-chair of the AIPN Oil and Gas Asset Valuation Workshop.

    View Profile

    Jim Thomas

    Jim is Executive Director of the S&P Global Commodity Insights Regulatory Compliance Consulting Group, with over 30 years of experience in environmental and regulatory management in the energy sector. Prior to joining S&P Global in 1999, Jim was a Senior Consultant with Petroconsultants, an Environmental Manager with Atkins Environment, a secondee to the UK Environment Agency and a Geochemical Analyst with BP. Within S&P Global, he has been responsible for the establishment and development of the regulatory consulting service, working on behalf of governments, national and international oil companies in over 40 different countries. Along with managing a team of legal and regulatory experts, he has been directly responsible for a wide range of different type of consulting services and assignments, each typically aimed at establishing best operational practices for governmental and non-governmental clients. The range of regulatory projects carried out includes compliance management system development, policy development, legal review and permit auditing, drafting petroleum legislation and H&S guidelines, fiscal benchmarking and analysis, negotiation support, licensing round management, technical due diligence and transaction support, organizational change and client training. The range of experience offered combined with consulting team expertise means that the Regulatory Group is well-placed to assist clients in making strategic and capital-intensive investment decisions.Jim holds a B.Sc. (Hons) Geology Decree (University of Leeds, UK) and a Ph.D. in Organic Geochemistry (University of Bristol, UK). He is a Fellow of the Geological Society and a member of the AIPN.

    View Profile

    Irena Agalliu

    Irena is an expert in international energy law and economics, worldwide fiscal arrangements, commercial risk and aboveground risk investment-related issues. She has extensive experience assessing commercial and regulatory risk and advising governments and NOCs on regulatory and contractual developments that impact E&P activities worldwide and assisting governments in formulating policies.Irena's major projects include assistance to the government of Mexico in development of industrial safety regulations for upstream oil and gas activities; assistance to the government of Colombia in development of offshore regulations, as well as development of fiscal and contractual framework for shale gas, tight oil and CBM; assistance to the legislature of North Dakota regarding fiscal policy solutions to enable CO2 EOR projects in the Bakken; assistance to the government of Angola on development of E&P regulations, LNG taxation and gas market regulations; and comparative analysis of fiscal systems for the United States Department of the Interior.Irena has provided independent expert review of proposed legislation governing petroleum upstream, midstream and downstream activities, revenue management in oil and gas, as well as local content participation, before legislatures of several African nations.Irena holds an LLM with distinction in Petroleum Law Policy and Economics from the University of Dundee, Scotland and a doctorate of jurisprudence from the University of Houston Law Center. She is a member of the State Bar of Texas and Association of International Petroleum Negotiators (AIPN). Irena was elected to the Board of AIPN in 2008 and served as vice president of external affairs for the 2009-2011 term and vice president of planning for the 2011-2012 term. She is the co-chair of the AIPN Oil and Gas Asset Valuation Workshop.

    View Profile

    Jim Thomas

    Jim is Executive Director of the S&P Global Commodity Insights Regulatory Compliance Consulting Group, with over 30 years of experience in environmental and regulatory management in the energy sector. Prior to joining S&P Global in 1999, Jim was a Senior Consultant with Petroconsultants, an Environmental Manager with Atkins Environment, a secondee to the UK Environment Agency and a Geochemical Analyst with BP. Within S&P Global, he has been responsible for the establishment and development of the regulatory consulting service, working on behalf of governments, national and international oil companies in over 40 different countries. Along with managing a team of legal and regulatory experts, he has been directly responsible for a wide range of different type of consulting services and assignments, each typically aimed at establishing best operational practices for governmental and non-governmental clients. The range of regulatory projects carried out includes compliance management system development, policy development, legal review and permit auditing, drafting petroleum legislation and H&S guidelines, fiscal benchmarking and analysis, negotiation support, licensing round management, technical due diligence and transaction support, organizational change and client training. The range of experience offered combined with consulting team expertise means that the Regulatory Group is well-placed to assist clients in making strategic and capital-intensive investment decisions.Jim holds a B.Sc. (Hons) Geology Decree (University of Leeds, UK) and a Ph.D. in Organic Geochemistry (University of Bristol, UK). He is a Fellow of the Geological Society and a member of the AIPN.

    View Profile

    Shawn Gallagher

    Shawn is an Associate Director in S&P Global Commodity Insights's regulatory group. She brings 18 years of experience in the oil and gas industry. She has advised governments and companies on a variety of topics including development of petroleum environmental and safety regulations, company analysis, unconventional oil and gas developments, and commercial, fiscal and economic terms. Previously, Shawn developed and managed the S&P Global Commodity Insights Herold Global Projects database, which tracked financial and operating details of significant upstream oil and gas development projects. Prior to joining S&P Global Commodity Insights, she worked in government and media relations for the National Petrochemical & Refining Association (NPRA) where she handled media requests, oversaw the website development and content, and tracked federal energy and environmental legislation and regulations relevant to the downstream sector.Shawn is a member of the State Bar of Texas. She has a B.A. from American University in Washington, DC, an M.B.A. from Thunderbird School of Global Management, and a J.D. from South Texas College of Law.

    View Profile

    Benjamin Morel

    Mr. Morel manages and contributes to a range of upstream energy regulatory consulting projects. His focus is on providing insight and analysis on energy regulatory systems across multiple jurisdictions globally. His team's clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments. Specific areas of expertise include providing regulatory research and insight on investment operations and fiscal systems, advising on energy contracts and rights allocation systems, drafting regulatory documents, litigation support and advising on practical compliance management at the project level. Mr. Morel's background is in commercial law and he holds a LLB (hons) from the Victoria University of Wellington, New Zealand where he focussed on the field of natural resources law and international environmental regulation. He also holds a Bachelor of Arts from the same institution and has been admitted as a barrister and solicitor of the High Court of New Zealand.

    View Profile

    Yelena Shliomenzon

    Yelena specializes in energy policy, legislation, and regulations, with particular emphasis on energy transition, technical, environmental, fiscal, contractual and permitting requirements, regulatory compliance and assurance management practices, regulatory risk management, stakeholders' engagement strategies, bid rounds and host government contracts.She is involved in designing and drafting energy, environmental, energy transition and petroleum policies, laws and regulations, upstream petroleum agreements, terms of reference for licensing rounds, litigation support and advising on practical compliance management at the project level.Her clients include a wide range of government authorities and private investors whose concerns touch on the regulation of capital-intensive energy investments.

    View Profile

    Industry Success Stories

    Mexico strengthens HSE regulations based on international standards and best practices

    After opening Mexico’s energy sector to foreign oil and gas investment, government agencies wanted to ensure industrial and operational safety and protect the environment. S&P Global identified international best practices, developed a proposal for new regulations and helped the government answer questions during the public comment period. The regulation was approved and published in 2016.

    Learn more

    Energy company resolves ongoing dispute with US tax authorities and saves $100 million

    When a client was preparing to stand trial in a US court, S&P Global provided an expert witness report that helped settle the issue without going to trial. By analyzing historic developments in contracting with international oil and gas companies in the Middle East and the evolution of foreign tax credits by Western governments, we supported the client’s case and helped it achieve major cost savings.

    Learn more

    Federation of Indian Petroleum Industry gains policy insights to incentivize EOR

    The government of India undertook a review of policies in order to promote enhanced oil recovery (EOR) projects across the country. S&P Global supported this effort by identifying best practices used in 25 jurisdictions worldwide, describing alternative policy solutions and assessing the impact of potential incentives on development of new oil fields and revenue accrual to the government.

    Learn more

    Oil company ensures compliance throughout lifecycle of multi-billion dollar investment

    A major oil company outsourced development of an enterprise management solution with the goal of achieving 100% compliance worldwide. S&P Global developed the system, populated it with the laws and regulations of a jurisdiction where the company has invested billions of dollars, completed a pilot project and supported it with consulting – providing the client with a competitive advantage.

    Learn more

    Mexico strengthens HSE regulations based on international standards and best practices

    After opening Mexico’s energy sector to foreign oil and gas investment, government agencies wanted to ensure industrial and operational safety and protect the environment. S&P Global identified international best practices, developed a proposal for new regulations and helped the government answer questions during the public comment period. The regulation was approved and published in 2016.

    Learn more

    Energy company resolves ongoing dispute with US tax authorities and saves $100 million

    When a client was preparing to stand trial in a US court, S&P Global provided an expert witness report that helped settle the issue without going to trial. By analyzing historic developments in contracting with international oil and gas companies in the Middle East and the evolution of foreign tax credits by Western governments, we supported the client’s case and helped it achieve major cost savings.

    Learn more

    Federation of Indian Petroleum Industry gains policy insights to incentivize EOR

    The government of India undertook a review of policies in order to promote enhanced oil recovery (EOR) projects across the country. S&P Global supported this effort by identifying best practices used in 25 jurisdictions worldwide, describing alternative policy solutions and assessing the impact of potential incentives on development of new oil fields and revenue accrual to the government.

    Learn more

    Oil company ensures compliance throughout lifecycle of multi-billion dollar investment

    A major oil company outsourced development of an enterprise management solution with the goal of achieving 100% compliance worldwide. S&P Global developed the system, populated it with the laws and regulations of a jurisdiction where the company has invested billions of dollars, completed a pilot project and supported it with consulting – providing the client with a competitive advantage.

    Learn more

    Mexico strengthens HSE regulations based on international standards and best practices

    After opening Mexico’s energy sector to foreign oil and gas investment, government agencies wanted to ensure industrial and operational safety and protect the environment. S&P Global identified international best practices, developed a proposal for new regulations and helped the government answer questions during the public comment period. The regulation was approved and published in 2016.

    Learn more

    Explore

    • Oil & Gas Upstream
    • Environmental Compliance
    • Engineering Standards Management
    • Exploration & Production (E&P)
    • Knowledge Management (KM)
    • Industry Monitoring and Trends
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