After the June 27, 2024, implementation of new financial assurance requirements at BOEM (the regulator for all offshore energy production in the US), a suit was filed by several states challenging the new regulations. Letters are going to clients requesting new financial assurance (including bonds) or modifications to existing bonds. The new BOEM regulations require that the Regional Directors at BOEM uniformly require financial assurance from lessees in the Gulf of Mexico who do not have an investment grade rating, eliminating the discretion previously afforded to the regulators. A panel comprised of Patrick Hennesy, National Underwriting Office for Sompo International, and Chairman of the SFAA Energy Subcommittee, Craig Gortner, Chief Underwriting Officer of Chubb Commercial Surety, John Hohlt, Head of Surety for CAC Specialty, a Houston-based surety broker, and Jason Kilpatrick, SVP, Energy Practice Leader at Applied Surety Underwriters will discuss the most recent BOEM regulations, impacts of the US Supreme Court’s Chevron ruling, and current state of the surety industry response to the new BOEM regulations.