THE SHELL LEAKS FILES: 21 SEPTEMBER 2026
SLF-2007-064
The Sakhalin Papers LIV: The Russian LNG Contract That Survived — Shell Announced Its Exit in 2022. Its 2025 Accounts Still List the Novatek Deal
In March 2022, Shell announced that it intended to withdraw from all Russian hydrocarbons, including LNG. Yet a long-term contract signed with Novatek in 2015 survived the withdrawal from Sakhalin, survived the disposal of Shell’s Russian retail business, and was still being reported by Shell in its 2025 Form 20-F, published in March 2026. Shell confirmed in 2023 that it was continuing to receive Yamal LNG cargoes under the agreement. The latest accounts confirm that the contract still exists — but do not establish whether Shell is still physically taking cargoes today. New European and British restrictions now place a significant regulatory deadline at the beginning of 2027.
Archive reference: SLF-2007-064
Collection: The Sakhalin Papers
Principal authenticated records: NOVATEK contract announcement, 4 June 2015; Shell Russia statements, February–March 2022; Shell Annual Reports 2022–2025; UK sanctions regulations and guidance; EU REPowerEU gas regulation
Contemporaneous reporting: Reuters, Interfax and Argus
Evidence standard: The existence of Shell’s long-term Novatek contract is established by Shell’s latest SEC filing. Continued physical receipt of Yamal LNG was confirmed by Shell in February 2023. No public evidence located for this instalment establishes that Shell continues taking individual Yamal cargoes in September 2026. Those are separate propositions and are treated separately below.
Introduction
Yesterday’s file followed the Sakhalin LNG contract that disappeared.
Today’s concerns the Russian LNG contract that did not.
On 4 June 2015, Novatek announced that its trading subsidiary, Novatek Gas & Power, had signed a long-term LNG agreement with:
Shell International Trading Middle East.
The quantity was approximately:
900,000 tonnes a year
for:
more than 20 years.
The LNG would come from the Yamal LNG project in the Russian Arctic. (Novatek)
Seven years later, Russia invaded Ukraine.
Shell announced that it intended to withdraw from Russian hydrocarbons.
The Sakhalin LNG contract subsequently collapsed.
The Novatek contract did not.
And Shell’s most recent annual filing still lists it.
1. The contract was signed when Russia was “of great importance” to Shell
The original Novatek announcement remains online.
It records that Novatek Gas & Power, a wholly owned Novatek trading subsidiary, signed the agreement with Shell International Trading Middle East on 4 June 2015.
The annual volume was approximately 0.9 million tonnes of LNG and the duration was more than twenty years. (Novatek)
At the time, Shell Vice-President of LNG Trading David Wells described Russia as:
“a country of great importance for Shell.”
That statement belonged to an entirely different geopolitical period.
Yamal LNG had not yet started production.
Shell was positioning itself as a major customer of Russia’s emerging Arctic LNG industry.
Argus contemporaneously described the agreement as a 20-year supply contract for about 900,000 tonnes annually from the planned 16.5-million-tonne-per-year Yamal project. (Argus Media)
2. This was not a Shell-owned LNG project
The distinction from Sakhalin is fundamental.
At Sakhalin II, Shell had been a shareholder and project participant as well as an LNG purchaser.
At Yamal, Shell’s relationship was commercial.
The seller was Novatek Gas & Power.
Shell International Trading Middle East was the buyer.
The LNG originated from Yamal LNG.
Shell did not need an equity interest in the producing project to incorporate those cargoes into its global LNG trading portfolio.
That portfolio structure matters because Shell buys substantial volumes of LNG from third parties and trades them alongside LNG produced by projects in which it owns equity.
Shell’s 2022 Annual Report described exactly that model: term purchases, third-party supplies, shipping flexibility and the ability to redirect cargoes between customers and markets.
3. Then came 8 March 2022
Twelve days after Russia’s full-scale invasion of Ukraine, Shell issued a major public announcement.
On 8 March 2022, Shell said it intended to withdraw from involvement in:
all Russian hydrocarbons, including crude oil, petroleum products, gas and LNG.
But the announcement contained an important qualification.
The withdrawal would occur:
“in a phased manner.”
(Shell)
Shell’s immediate action was to stop spot purchases of Russian crude oil.
The company did not announce that every pre-existing long-term Russian supply agreement had been cancelled that day.
That distinction subsequently became central to the Novatek contract.
4. “Phased withdrawal” did not mean every contract vanished
The practical problem was contractual.
A corporate decision to withdraw from a country does not necessarily extinguish long-term commercial obligations.
Shell could dispose of an equity investment.
It could close a retail operation.
It could stop making spot purchases.
But long-term sales-and-purchase agreements may contain obligations extending for decades, together with termination provisions, force-majeure provisions, governing-law clauses and dispute-resolution mechanisms.
Those contractual terms are not publicly available for the Shell-Novatek agreement.
Accordingly, this archive cannot state that Shell was free simply to walk away from it in March 2022.
Nor can it state that Shell was legally compelled to continue indefinitely.
The contract itself has not been published.
5. Shell stopped buying Russian LNG on the spot market
Shell’s later reporting makes an important distinction.
After its March 2022 announcement, Shell ceased spot purchases of Russian LNG.
It also allowed various oil, oil-product and pipeline-gas arrangements to expire.
But two long-term Russian LNG contracts remained at the end of 2022.
One concerned Sakhalin.
The other concerned Novatek and Yamal LNG. (Interfax)
This distinction between spot transactions and long-term contractual purchases explains much of what otherwise appears contradictory.
Shell was withdrawing.
But some legacy contracts continued to exist.
6. In February 2023 Shell confirmed that Yamal cargoes were still arriving
This is the strongest public evidence that the Novatek contract was not merely an accounting relic.
On 2 February 2023, a Shell spokesperson told Reuters that Shell was:
still receiving Russian LNG cargoes under its long-term Novatek contract.
Reuters identified the arrangement as the more-than-20-year agreement for approximately 900,000 tonnes annually from Yamal LNG. (Pipeline and Gas Journal)
Interfax reported the same contractual distinction.
Shell was no longer receiving cargoes from Sakhalin.
But the Novatek/Yamal agreement remained. (Interfax)
This was therefore not simply a dormant contract sitting on Shell’s books in early 2023.
Shell publicly acknowledged continuing performance.
7. The contrast with Sakhalin could hardly be clearer
By February 2023, Shell had two very different Russian LNG stories.
Sakhalin
Cargoes had stopped.
Shell was examining its legal position.
Shell subsequently concluded that the old Sakhalin Energy company had renounced the contract through non-performance and that the agreement stood terminated.
Yamal
Cargoes were still being received.
The Novatek contract remained in force.
That divergent treatment is documented in Shell’s own subsequent filings. (SEC)
Whatever the broader political policy of withdrawing from Russian hydrocarbons, the two long-term LNG contracts followed completely different legal paths.
8. Shell continued disclosing the Novatek contract
The annual-report trail is unusually revealing.
Shell’s 2023 Form 20-F said:
“Shell still holds one long-term LNG purchase contract with a Novatek entity.” (SEC)
Shell’s 2024 Form 20-F repeated the disclosure. (SEC)
Then came the 2025 Form 20-F, filed with the US Securities and Exchange Commission on 12 March 2026.
Again Shell stated that in 2022 it had announced its intention to withdraw in a phased manner from all Russian hydrocarbons.
Again it recorded its residual Sakhalin shareholding.
And again it stated:
“Shell still holds one long-term LNG purchase contract with a Novatek entity.”
(SEC)
Four years after the withdrawal announcement, the contract remained sufficiently relevant to be disclosed in Shell’s principal annual regulatory filing.
9. What the 2025 filing does — and does not — establish
The wording needs to be read precisely.
Shell says it holds the contract.
That establishes the continuing contractual relationship.
But the filing does not say:
how many Yamal cargoes Shell received in 2025;
whether it received any in early 2026;
where any cargoes were delivered;
what Shell paid for them;
what profits or losses arose;
whether the contract has been amended;
or whether Shell and Novatek are negotiating its termination.
No such conclusions should be inserted into the evidential gap.
The latest authenticated Shell record establishes the existence of the contract.
The latest explicit confirmation located that Shell was physically receiving cargoes dates from February 2023. (Pipeline and Gas Journal)
That distinction matters.
10. The UK had already banned Russian LNG from entering Britain
The continuation of Shell’s contract should not be confused with continued importation of Russian LNG into the United Kingdom.
The UK government introduced a prohibition on Russian LNG imports taking effect on:
1 January 2023.
The measure prohibited Russian-origin or Russian-consigned LNG from entering the UK and covered acquisition where the intention was to bring the LNG into Britain. (GOV.UK)
By May 2023, the UK government said Britain had gone a full year without importing Russian gas. (GOV.UK)
Thus a Shell group company holding a Russian LNG purchase contract did not mean those cargoes were entering Britain.
Shell is a global LNG trader.
Cargoes can be marketed internationally.
11. Europe initially took a different route
For several years after the invasion, Russian LNG continued flowing into European markets even while Russian oil and coal faced much broader prohibitions.
That explains why the Novatek contract could remain commercially relevant after February 2022.
The legal position has since changed substantially.
In January 2026, the European Union formally adopted rules providing for a stepwise prohibition on imports of Russian pipeline gas and LNG.
For long-term Russian LNG contracts, the EU prohibition takes effect on:
1 January 2027.
(Council of the European Union)
The regulation specifically provides transitional treatment for existing contracts rather than treating them as though they had ceased to exist retrospectively.
That is particularly relevant to an agreement signed as far back as 2015.
12. Britain has also tightened the LNG transport regime
The United Kingdom has since moved beyond the original prohibition on LNG entering Britain.
In May 2026, the government published a general trade licence concerning new prohibitions on the maritime transportation of Russian LNG and associated services.
The licence expires on:
1 January 2027.
The government also states that an exception exists until that date for certain obligations arising under contracts concluded before 17 June 2025, subject to the regulatory conditions. (GOV.UK)
Whether particular Shell activities fall within any prohibition, licence or exception would depend on the entities, vessels, services, destinations and contractual arrangements involved.
This archive makes no finding on that legal question.
What is established is that both British and EU policy now point toward 1 January 2027 as a major date for Russian LNG trading arrangements.
13. The contract may be much longer than the remaining regulatory window
The original agreement was for more than twenty years.
It was signed in 2015 for LNG from a project expected to start production in 2017.
The publicly available announcement does not provide an exact contractual expiry date.
It is therefore unsafe to manufacture one.
But a contract of more than twenty years was plainly intended to continue well beyond 2027 unless terminated or otherwise affected by law. (Novatek)
This creates the central tension now visible in the documentary record:
commercial contract duration versus sanctions and regulatory withdrawal deadlines.
A contract drafted to operate for decades is encountering a legal environment that changed fundamentally within a few years.
14. There is no identified public court battle over the Yamal agreement
The Sakhalin story has generated litigation.
The Gazprom Export pipeline-gas dispute has generated a pending Moscow claim of approximately €1.5 billion.
No comparable publicly identified court judgment or arbitral award concerning the Shell-Novatek Yamal LNG purchase contract has been located for this instalment.
That does not prove there has been no confidential negotiation or arbitration.
LNG contracts frequently provide for private dispute resolution.
What can be said is narrower:
Shell continues to report the contract rather than reporting it as terminated.
That makes the position markedly different from the Sakhalin contract.
15. Yamal LNG must not be confused with Arctic LNG 2
There is another important distinction.
The Shell contract discussed here concerns:
Yamal LNG.
It should not be confused with Novatek’s newer:
Arctic LNG 2.
The projects have different ownership structures, histories and sanctions exposure.
Yamal LNG entered production years before the invasion.
Arctic LNG 2 became a major target of subsequent Western sanctions.
Shell’s 2015 long-term contract specifically referred to LNG from Yamal LNG. (Novatek)
Conflating the two would distort both the contractual and sanctions history.
16. Why did this Russian contract survive when Sakhalin did not?
The public record supports several factual distinctions.
The Sakhalin operator was forcibly restructured by presidential decree.
The old Sakhalin counterparty stopped performing Shell’s LNG purchase agreement.
Shell consequently treated that contract as renounced and terminated.
No equivalent cessation of performance has been publicly established for the Novatek agreement.
Indeed, Shell expressly confirmed in February 2023 that Yamal cargoes were still being received. (Pipeline and Gas Journal)
The simplest documentary explanation is therefore also the safest:
Sakhalin stopped performing. Novatek did not — at least as of the last public confirmation of physical deliveries.
The later regulatory environment may ultimately determine what happens next.
Documentary Findings
Established
On 4 June 2015, Novatek Gas & Power signed a long-term LNG supply contract with Shell International Trading Middle East. (Novatek)
The contract provided approximately 900,000 tonnes of Yamal LNG annually for more than twenty years. (Novatek)
On 8 March 2022, Shell announced its intention to withdraw in a phased manner from all Russian hydrocarbons, expressly including LNG. (Shell)
Shell ceased Russian LNG spot purchases but retained long-term contractual relationships. (Interfax)
In February 2023, a Shell spokesperson confirmed to Reuters that Shell was still receiving Russian LNG cargoes under the Novatek contract. (Pipeline and Gas Journal)
Shell’s Sakhalin LNG contract subsequently terminated following non-performance by its counterparty, while the Novatek contract remained.
Shell’s 2023, 2024 and 2025 annual regulatory filings all continued to identify one long-term LNG purchase contract with a Novatek entity. (SEC)
Shell filed its 2025 Form 20-F on 12 March 2026. (Shell)
The UK prohibited Russian LNG imports into Britain from 1 January 2023. (GOV.UK)
The EU has adopted a prohibition on Russian LNG imports under long-term contracts taking effect from 1 January 2027. (Council of the European Union)
The UK has also introduced restrictions concerning maritime transport of Russian LNG, with transitional provisions and a general licence running until 1 January 2027. (GOV.UK)
Established only to February 2023
Shell was physically receiving Yamal LNG cargoes under the Novatek agreement.
The Reuters report attributes that information directly to a Shell spokesperson. (Pipeline and Gas Journal)
Not established
It is not established from the public material examined for this file that Shell is physically receiving Yamal LNG cargoes in September 2026.
It is not established how many cargoes Shell received after February 2023.
It is not established where any subsequent cargoes were delivered.
It is not established what revenue, profit or loss Shell derived from the contract after the invasion.
It is not established whether the contract has since been amended.
It is not established that Shell is in breach of British, European or other sanctions.
It is not established that Novatek is in breach of the contract.
It is not established that Shell has commenced arbitration or litigation concerning the agreement.
It is not established what will happen to the contract when the new European and British restrictions reach their January 2027 stage.
Commentary
The importance of this contract lies less in accusation than in chronology.
Shell’s public statement in March 2022 was easily understood as:
Shell is leaving Russian hydrocarbons.
But contracts operate differently from headlines.
Four years later, Shell’s own SEC filing still records a Russian LNG purchase agreement.
That does not demonstrate deception.
It demonstrates how complicated an actual corporate withdrawal can be.
Assets can be sold.
Joint ventures can be abandoned.
Retail businesses can change hands.
Spot purchases can stop immediately.
Long-term contracts are another matter.
They come with counterparties, governing law, contractual remedies and potentially enormous financial consequences if they are broken.
The Novatek agreement appears to be one of the clearest surviving examples of that reality.
The deeper significance
The documentary record now allows a more precise description of Shell’s Russian exit.
Shell did not move from:
Russia
to:
no Russia
on a single date.
Instead, different relationships unwound at different speeds.
Nord Stream 2 ended.
The retail business was sold.
Salym was exited.
Sakhalin operating participation disappeared.
The Sakhalin LNG contract ceased performing and was treated as terminated.
The Gazprom pipeline-gas relationship became litigation.
The old Sakhalin shareholding remained on Shell’s books.
And the Novatek LNG purchase contract survived.
That is the history the annual reports disclose.
The clock is now running toward 2027
There is also a new element that did not exist when this series began reconstructing the post-2022 story.
Governments have now imposed deadlines that may finally overtake the legacy commercial arrangements.
The EU’s date for long-term Russian LNG imports is:
1 January 2027.
British maritime LNG restrictions and current transitional provisions also focus on:
1 January 2027.
Shell’s next annual report should therefore be particularly important.
If the Novatek sentence disappears, changes wording or is accompanied by a termination disclosure, that will be documentary evidence of another stage in Shell’s Russian withdrawal.
Until then, the latest authenticated position is the one Shell itself filed with the SEC:
the long-term Novatek LNG contract still exists.
Source Record
NOVATEK’s original 4 June 2015 announcement records the counterparties, Yamal LNG source, annual volume of approximately 0.9 million tonnes and duration exceeding twenty years. (Novatek)
NOVATEK — Long-term LNG contract with Shell, 4 June 2015
Shell’s 8 March 2022 statement records its intention to withdraw from all Russian hydrocarbons, including LNG, in a phased manner. (Shell)
Shell — Statements concerning withdrawal from Russian oil and gas
Reuters reported on 2 February 2023, citing a Shell spokesperson, that Shell was still receiving cargoes under its long-term Novatek contract. (Pipeline and Gas Journal)
Reuters report — Shell still receiving LNG under Novatek contract
Interfax separately documented Shell’s two remaining Russian LNG contracts and the cessation of Sakhalin deliveries. (Interfax)
Interfax — Shell LNG contract position, 2 February 2023
Shell’s 2025 Form 20-F contains the latest authenticated disclosure located for this file: Shell still holds one long-term LNG purchase contract with a Novatek entity. (SEC)
Shell confirmed that the 2025 Form 20-F was filed on 12 March 2026. (Shell)
Shell — 2025 Form 20-F filing announcement
The UK’s 2022 sanctions notice records the prohibition on Russian LNG imports entering into force on 1 January 2023. (GOV.UK)
UK Government — Russian LNG import prohibition
The Council of the European Union records the new transition timetable under which long-term Russian LNG imports are prohibited from 1 January 2027. (Council of the European Union)
Council of the EU — Ending Russian energy imports
The UK government’s May 2026 guidance records maritime-transport restrictions, the general licence expiring on 1 January 2027, and the separate transitional exception for qualifying pre-17 June 2025 contracts. (GOV.UK)
UK Government — Maritime transportation of Russian LNG
Archive disclaimer: This instalment distinguishes between the continuing existence of a contract and evidence of continuing physical deliveries. Shell’s latest SEC filing establishes the former. The latest explicit public confirmation located of Shell receiving Yamal cargoes dates from February 2023. No allegation of sanctions violation is made. Questions concerning the application of sanctions to individual entities, cargoes or services would require transaction-specific legal analysis.
Site-wide disclaimer applies.
Next instalment
The Sakhalin Papers LV: The Scientist Who Walked Away — Rick Steiner, the Independent Review and the Warnings Shell Faced Before Sakhalin II Became a Global Controversy
The modern Russian legal aftermath has now taken us from:
Shell’s 2022 withdrawal
through:
the confiscated Sakhalin operating interest,
the 94-billion-rouble compensation,
the €1.5-billion Gazprom lawsuit,
the vanished Sakhalin LNG contract,
and finally:
the Novatek agreement that survived.
The next file returns to an earlier part of the chronology.
Long before Putin’s 2022 restructuring, an independent scientist examining Sakhalin II was warning about environmental risk, project governance and what he believed the review process was failing adequately to confront.
His name was:
Rick Steiner.
In January 2005, Steiner supplied additional proposed text to the Independent Scientific Review Panel examining Sakhalin II.
Later that year, after the PA-B tow-out episode, he resigned.
His contemporaneous papers have survived.
Some were recently supplied directly to this archive.
The next instalment asks a different question:
What exactly was Rick Steiner warning about in 2004–2005 — what did the independent review ultimately say, what did it leave out, and how did subsequent events compare with those warnings?
*This website and sisters royaldutchshellgroup.com, shellnazihistory.com, royaldutchshell.website, johndonovan.website, shellnews.net, and shellwikipedia.com, are owned by John Donovan - more information here. There is also a Wikipedia segment, the Shell DPA Files, "Shell and the Spies", the Shell Leaks files, the Independent Shell Archive, as well as books written and published by John Donovan - Kindle eBooks. Timeline of the Donovan Shell Feud. Toxic History of Royal Dutch Shell Group. Shell and the Donovans: The Full Media Record — 550+ Articles, 110 Books, 40 Years. *All conjured up by internet wizz, Nick Gill.
