THE SHELL LEAKS FILES — 25 OCTOBER 2026
SLF-2007-098
The Sakhalin Papers LXXXVIII: The Thirty-Day Exit — Washington’s October 2020 Sanctions Ultimatum and the Companies Caught Between Two Legal Systems
On 20 October 2020, the United States gave companies supporting Nord Stream 2 a sharply defined choice: end certain activities within 30 days or face potential sanctions. The warning extended to businesses supplying equipment, facilities and services to the vessels needed to complete the Russian gas pipeline. An examination of the original Federal Register notice, Shell’s financial disclosures, German parliamentary records and contemporaneous reporting reveals how Washington used an expansive interpretation of existing legislation to intensify pressure on a project already facing serious regulatory and political difficulties.
Archive reference: SLF-2007-098
Publication date: 25 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-097, The Sakhalin Papers LXXXVII, 24 October 2026
Principal sources: US Department of State Public Notice 11236; Federal Register, 5 November 2020; Protecting Europe’s Energy Security Act of 2019; German Bundestag parliamentary records; European External Action Service statements; Shell’s authenticated April 2017 financing announcement; Shell’s 2022 Annual Report filed with the US Securities and Exchange Commission; contemporary S&P Global and Reuters reporting; and subsequent US government sanctions records.
THE SHELL LEAKS FILES — 24 OCTOBER 2026























