THE SHELL LEAKS FILES: 19 SEPTEMBER 2026
SLF-2007-062
The Sakhalin Papers LII: The Type-C Account — How a 2022 Rouble-Payment Dispute Became a €1.5 Billion Claim Against Shell
Russia’s Prosecutor General is seeking approximately €1.5 billion from Shell Energy Europe over disputed 2022 gas payments — and wants approximately 94 billion roubles set aside for Shell’s Sakhalin compensation used against the claim. The two sums arise from different transactions. Moscow has joined them together in one closed-door lawsuit. Shell says liability remains uncertain. As of July 2026, the next reported hearing was not due until January 2027.
The previous instalment followed the 94.8 billion roubles attached to Shell’s former Sakhalin II interest.
The money did not simply reach Shell.
Instead, approximately 94 billion roubles became trapped inside Russia’s post-2022 financial machinery and subsequently appeared in a lawsuit concerning an entirely different commercial relationship:
pipeline gas supplied by Gazprom Export to Shell Energy Europe for Germany.
That distinction is essential.
The Russian claim now links:
Shell’s withdrawal from Sakhalin II;
a 2022 gas-supply contract;
Russia’s demand that foreign buyers use its new rouble-payment mechanism;
and:
the proceeds associated with Shell’s former Sakhalin interest.
The result is one of the strangest legal afterlives of Shell’s withdrawal from Russia.
1. The dispute began with pipeline gas — not Sakhalin LNG
The €1.5 billion claim now before the Moscow Arbitration Court should not be mistaken for a claim that Shell failed to pay for Sakhalin II LNG.
It concerns a separate contract between Gazprom Export and Shell Energy Europe Limited.
Contemporaneous reporting in 2022 recorded that the contract provided for up to 1.2 billion cubic metres of pipeline gas per year for Germany. (interfax.com)
That contract became caught in the confrontation over Russia’s new gas-payment rules following the invasion of Ukraine.
On 31 March 2022, President Vladimir Putin signed Decree No. 172 establishing a new payment procedure for certain foreign buyers of Russian gas.
Under the Russian mechanism, buyers from designated states were required to use accounts at Gazprombank through which foreign-currency payments would ultimately be converted into roubles. (interfax.com)
Shell did not accept the new requirement.
2. Gazprom cut Shell’s gas supply on 1 June 2022
On 31 May 2022, Gazprom Export said Shell Energy Europe had informed it that the company did not intend to make payment in roubles under the new Russian system.
Gazprom said that, by the payment deadline, it had not received the required rouble payment for gas supplied in April.
It announced that supply would therefore be suspended from 1 June 2022. (interfax.com)
Reuters contemporaneously reported the same event: Gazprom cut Shell Energy’s gas supply into Germany after Shell declined to comply with the rouble-payment demand. (euronews)
This point requires careful wording.
What is established is that:
Gazprom demanded payment under its new rouble mechanism.
Shell declined to adopt that mechanism.
Gazprom said compliant payment had not been received.
Gazprom stopped deliveries.
That does not, by itself, establish that Shell was contractually obliged under the original agreement to adopt Russia’s newly imposed payment system.
That question is part of the dispute.
3. The quarrel then disappeared from public view
For more than two years, the Shell-Gazprom payment dispute attracted comparatively little public attention.
Shell continued its phased withdrawal from Russian hydrocarbons.
Its Sakhalin II interest became subject to the separate restructuring examined in the previous instalments.
Gazprom’s Russian-controlled Sakhalin vehicle ultimately acquired the unclaimed replacement-company interest for 94.8 billion roubles.
Those events appeared to belong to different legal compartments.
One concerned:
gas purchased by Shell Energy Europe for Germany.
The other concerned:
Shell’s former equity position in Sakhalin II.
By 2024, Russia had joined them together.
4. The Prosecutor General filed suit
On 2 October 2024, Russia’s Prosecutor General filed proceedings in the Moscow Arbitration Court against Shell plc and several Shell-group entities.
The public case number is:
A40-241354/2024
The defendants named in public reporting included Shell plc, Shell Energy Europe Limited, several Dutch Shell companies and Shell NefteGaz Development LLC. (ПРАВО.Ru)
Gazprom Export, the Russian Energy Ministry, Sakhalin Energy LLC, the old Sakhalin Energy Investment Company and the Sakhalin regional authorities were among the third parties identified in reporting on the case. (interfax.com)
The Moscow court accepted the proceedings on 11 October 2024. A reproduced court decision identifies the case as Prosecutor-General’s Office of the Russian Federation v Shell plc and others. (Jus Mundi)
At that point, however, the detailed basis of the claim was not publicly available.
The statement of claim itself was not published in the public case card. (ПРАВО.Ru)
5. Russia initially described damages of more than €1 billion
On 15 October 2024, the Moscow court press service told Interfax that the Prosecutor General was seeking damages exceeding €1 billion.
Contemporaneous reporting noted that the amount was broadly comparable with the rouble value associated with Shell’s former Sakhalin interest. (interfax.com)
But at that stage the precise connection had not been publicly explained.
That explanation would eventually come from Shell itself.
6. The courtroom was closed
On 11 December 2024, the Moscow Arbitration Court ordered that the proceedings be heard behind closed doors.
According to Interfax, most participants supported closed hearings because the case materials contained commercially confidential information.
The Prosecutor General also argued that public disclosure of information from the proceedings could increase sanctions pressure on Russia. (Interfax.ru)
That decision has an obvious consequence for this archive.
There is no complete public evidential record from which an outsider can independently reconstruct the parties’ contractual arguments.
The Shell Leaks Files therefore cannot responsibly declare which side is legally correct.
The available record establishes what each side is alleging.
It does not establish liability.
7. Shell eventually disclosed what Russia was seeking
The most important public description came from Shell’s own annual reporting.
Shell’s 2024 Form 20-F stated that the Russian prosecutor sought three principal forms of relief.
First, declarations that Shell had acted unlawfully in withdrawing support from Sakhalin Energy Investment Company.
Second, approximately:
€1.5 billion
from Shell Energy Europe Limited to Gazprom Export for alleged unpaid gas deliveries during 2022.
Third, permission for Gazprom Export to take approximately:
94 billion roubles
purportedly reserved for Shell as Sakhalin equity compensation in a Type-C account, and apply that amount against part of the alleged Shell Energy Europe debt. (SEC)
That disclosure transformed the understanding of the case.
The Sakhalin compensation and the German gas-supply dispute had become legally connected.
8. Two separate commercial relationships were being joined together
This is the central documentary point.
The €1.5 billion claim relates to alleged non-payment for gas under the Gazprom Export–Shell Energy Europe relationship.
The 94 billion roubles relates to compensation associated with Shell’s former Sakhalin position.
They are not the same transaction.
Russia’s case seeks to connect them through set-off.
In simplified terms, the prosecutorial position described by Shell is:
Shell Energy Europe allegedly owes Gazprom Export money.
Money is allegedly being held for Shell arising from Sakhalin.
Russia wants the Sakhalin money applied against the alleged gas debt.
That is the connection.
9. What is a Type-C account?
Type-C accounts became an important part of Russia’s financial response to Western sanctions after the February 2022 invasion of Ukraine.
They are special rouble accounts used in certain circumstances to fulfil obligations to creditors associated with states Russia categorises as “unfriendly”.
The account structure can mean that an obligation is treated as paid within the Russian system even though the foreign creditor cannot freely repatriate or use the funds in the manner normally expected in an international commercial transaction. (lidings.com)
For Shell, however, one qualification is particularly important.
Shell’s annual report does not simply state as an uncontested fact that 94 billion roubles belongs to Shell.
It describes the money as approximately 94 billion roubles “purportedly set aside” for Shell’s Sakhalin equity compensation. (SEC)
That wording preserves Shell’s legal position.
So should this archive.
10. Shell sought postponements
The litigation did not move rapidly towards judgment.
Shell’s 2024 Form 20-F recorded that Shell Energy Europe filed a written postponement motion on 30 January 2025.
Following a hearing on 14 February 2025, the case was postponed until 14 April. (SEC)
Further delays followed.
On 14 April 2025, the court adjourned proceedings until 11 June. (Interfax.ru)
On 11 June, the next hearing was fixed for 25 August. (Interfax.ru)
On 25 August, another postponement took the case to 26 November.
Interfax reported that Shell Energy Europe had again sought an adjournment and that the prosecutor had submitted further written explanations. (Interfax.ru)
The repeated adjournments show that this was not being disposed of summarily.
11. Shell’s latest annual report still records no resolution
Shell’s 2025 Annual Report and Accounts, published on 12 March 2026, provides the most recent authenticated Shell description located for this instalment.
The language is notably cautious.
Shell again states that the prosecutor seeks:
approximately €1.5 billion;
access to approximately 94 billion roubles of alleged Sakhalin compensation;
and declarations concerning Shell’s conduct in relation to Sakhalin Energy Investment Company.
Then comes the critical sentence:
“The proceedings are ongoing.” (SEC)
Shell further says that it cannot reliably estimate either the magnitude or timing of any possible obligation or payment, or even whether payment will ultimately be due.
The company records a high degree of uncertainty over the outcome and its possible effects. (SEC)
That is Shell’s own audited reporting position.
12. The case is now reported to extend into 2027
There is a more recent procedural development.
A report dated 8 July 2026, citing the Moscow Arbitration Court case file, states that the next continuation of the proceedings is scheduled for:
18 January 2027
The reported claim remains €1.5 billion. (https://x-compliance.ru)
That means that, as of the latest public procedural information located for this file, the litigation remains unresolved more than two years after the Prosecutor General first filed suit.
No final Russian judgment has been identified for this instalment.
Accordingly, the archive treats the allegations as pending.
13. The 2022 gas dispute deserves particular care
The Russian claim is often summarised as being for “unpaid gas.”
That shorthand risks obscuring the contractual dispute.
Contemporaneous reporting establishes that Gazprom demanded compliance with a payment mechanism introduced by Russian presidential decree after the original gas relationship was already operating.
Gazprom said Shell refused to pay in roubles.
Shell did not accept the new payment terms.
Gazprom then halted supplies. (interfax.com)
The later Russian prosecutor describes sums as unpaid.
But the public record available here does not contain the full gas contract, the payment clauses, the parties’ contractual notices, or the evidence being considered in the closed Moscow proceedings.
It would therefore be improper to convert the Russian allegation into an established debt.
14. The same caution applies to Russia’s allegation that Shell “abandoned” Sakhalin
Shell announced in 2022 that it intended to withdraw from Russian hydrocarbons following Russia’s invasion of Ukraine.
Russia subsequently restructured Sakhalin II under presidential decree.
Shell declined to take an interest in the newly created Russian operator.
Mitsui and Mitsubishi remained.
The Russian prosecutor now seeks declarations concerning what Shell’s annual report describes as alleged unlawful abandonment of support for Sakhalin Energy Investment Company. (SEC)
That allegation forms part of the pending proceedings.
It has not been established by a final judgment located for this instalment.
15. Yet Shell has not entirely disappeared from the old corporate structure
Shell’s 2025 annual report continues to state that the company holds a 27.5% minus one share interest in Sakhalin Energy Investment Company Ltd, the old Bermuda-incorporated company. (SEC)
As previous instalments have documented, Russia transferred the operational rights and obligations into a new Russian company.
Shell did not join that company.
The result is an extraordinary corporate split:
Shell retains shares in the predecessor entity;
the operating project is controlled through the Russian successor;
the economic value associated with Shell’s former operating interest was priced at 94.8 billion roubles;
and Russia now wants approximately that compensation pool applied against a separate gas claim.
16. What the case does not establish
The litigation does not currently establish that Shell owes Gazprom Export €1.5 billion.
It does not establish that the 94 billion roubles is freely available property of Shell.
It does not establish that Russia’s post-2022 rouble-payment mechanism was contractually binding upon Shell Energy Europe under the pre-existing agreement.
It does not establish that Shell’s decision not to participate in the replacement Sakhalin operator was unlawful.
And it does not establish that Gazprom Export is ultimately entitled to set one claim against the other.
Those are precisely the matters that remain contested.
Documentary Findings
Established: Shell Energy Europe had a Gazprom Export contract for up to 1.2 billion cubic metres of gas annually for Germany. (interfax.com)
Established: In May 2022, Shell Energy Europe informed Gazprom Export that it would not adopt the new rouble-payment arrangement demanded under Russian Presidential Decree No. 172. (interfax.com)
Established: Gazprom suspended supplies from 1 June 2022 after stating that the required rouble payment had not been received. (interfax.com)
Established: Russia’s Prosecutor General filed Moscow proceedings against Shell-group entities on 2 October 2024 under Case No. A40-241354/2024. (ПРАВО.Ru)
Established: The proceedings were placed behind closed doors in December 2024. (Interfax.ru)
Established: Shell says the prosecutor seeks approximately €1.5 billion from Shell Energy Europe for alleged unpaid 2022 gas deliveries. (SEC)
Established: Shell says the prosecutor also seeks authority for Gazprom Export to take approximately 94 billion roubles purportedly reserved for Shell’s Sakhalin equity compensation from a Type-C account and apply it against part of the alleged debt. (SEC)
Established: Shell’s 2025 Annual Report, published on 12 March 2026, describes the case as ongoing and says the company cannot reliably estimate any eventual payment obligation. (SEC)
Established: Public procedural reporting dated 8 July 2026 states that the next continuation of the proceedings is scheduled for 18 January 2027. (https://x-compliance.ru)
Alleged: That Shell Energy Europe owes approximately €1.5 billion for unpaid gas.
Alleged: That Shell unlawfully withdrew support from Sakhalin Energy Investment Company.
Not established: That Shell is ultimately liable for either allegation.
Not established: That Gazprom Export is entitled to the 94 billion-rouble compensation pool.
Not established: That the Type-C funds will ever be freely recoverable by Shell.
Commentary
The most revealing feature of this case is not simply its size.
It is the way separate strands of Shell’s Russian exit have become entangled.
A gas-purchase contract for Germany.
A presidential decree changing the currency-payment mechanism.
Shell’s refusal to adopt that mechanism.
Gazprom’s suspension of supply.
Shell’s withdrawal from Sakhalin.
Russia’s transfer of the project to a new operator.
The 94.8 billion-rouble valuation of Shell’s former interest.
A restricted Type-C account.
Then a Prosecutor General’s lawsuit attempting to connect them.
Four years after Shell announced that it would withdraw from Russian hydrocarbons, the company’s Russian relationship is still generating unresolved legal consequences.
That is the point the official record now establishes.
Leaving the country commercially did not mean leaving its legal system behind.
The evidential limitation matters
There is also a larger archival lesson.
The Moscow case is closed to the public.
The full pleadings are not publicly available.
The underlying contracts are not before us.
The court has not issued a publicly identified final judgment.
In those circumstances, certainty would be manufactured.
The proper documentary approach is narrower:
record what Russia alleges;
record what Shell says;
record what the contemporaneous evidence shows;
record the procedural history;
and stop where the evidence stops.
That discipline is especially important when the dispute sits at the intersection of sanctions, war, energy security and state-controlled companies.
Source Record
Shell’s latest authenticated description appears in its 2025 Annual Report and Accounts, published 12 March 2026. It states that the Moscow proceedings remain ongoing, identifies the €1.5 billion claim and the attempted use of approximately 94 billion roubles from a Type-C account, and records Shell’s inability to estimate the eventual financial outcome. (SEC)
Shell Annual Report and Accounts 2025
The SEC-hosted Shell filing provides the same authenticated disclosure.
SEC — Shell Annual Report and Accounts 2025
The original Moscow case is publicly identified as A40-241354/2024. Pravo reported the filing and noted that the statement of claim itself was not available in the public case card. (ПРАВО.Ru)
Pravo — Prosecutor files case against Shell
The Moscow court’s 11 October 2024 decision accepting the case is reproduced by Jus Mundi. (Jus Mundi)
Jus Mundi — Prosecutor-General’s Office v Shell
Interfax recorded the December 2024 decision to close the proceedings to the public and the repeated 2025 adjournments. (Interfax.ru)
Interfax — Court orders closed hearing, 11 December 2024
Interfax — Hearing moved to 11 June 2025
Interfax — Hearing moved to 25 August 2025
Interfax — Hearing moved to 26 November 2025
The 2022 gas-payment dispute was documented contemporaneously by Gazprom statements carried by Interfax and Reuters reporting. (interfax.com)
Interfax — Gazprom halts gas supplies to Shell, 1 June 2022
Reuters report — Gazprom cuts Shell Energy supply, 1 June 2022
The latest procedural report located for this instalment, dated 8 July 2026 and citing the court docket, states that the next hearing is scheduled for 18 January 2027. (https://x-compliance.ru)
X-Compliance — Shell hearing continued to January 2027
Archive disclaimer: Russian prosecutorial allegations are identified as allegations. Shell’s descriptions of the case are attributed to Shell. The absence of public pleadings and the closed nature of the Moscow proceedings prevent an independent assessment of the full contractual evidence. This instalment therefore makes no finding that Shell owes the sums claimed, that Russia’s rouble-payment mechanism governed the original contract, or that Gazprom Export is legally entitled to Shell’s Sakhalin compensation.
Site-wide disclaimer applies.
Next instalment
The Sakhalin Papers LIII: The Missing LNG Cargoes — Shell Had a Sakhalin Contract Running to 2028. Then the Deliveries Stopped
There is another contract in the Sakhalin story.
This one did concern LNG.
Shell disclosed that it had a long-term agreement with the old Sakhalin Energy company that was due to run until 2028.
After Russia transferred the project into the replacement Russian operator, Shell said it stopped receiving cargoes due under that contract.
By February 2023, Shell was publicly saying that it was monitoring developments and evaluating its legal options. (interfax.com)
The next file follows those missing cargoes:
What exactly did Shell lose when Sakhalin LNG stopped arriving, what contractual rights survived the Russian restructuring, and did Shell ever obtain compensation for supplies that were supposed to continue for years after its departure?
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