
THE SHELL LEAKS FILES: 26 SEPTEMBER 2026
SLF-2007-069
The Sakhalin Papers LIX: The 120-Day Test — When Shell’s $20 Billion Project Was Put Out for Public Judgment
In December 2005, the European Bank for Reconstruction and Development decided that Sakhalin II’s environmental and social documentation was sufficiently developed to enter formal public consultation. That was not project approval and it was not a loan decision. During the following 120 days, critics challenged the project in London, Moscow, Sakhalin and Hokkaido over whales, salmon rivers, seismic risk, oil-spill preparedness and consultation itself. Sakhalin Energy maintained that it was complying with Russian law and improving its environmental controls. Then, before the financing question could be resolved, the argument changed character. Russian regulators moved against a crucial environmental approval, Gazprom was seeking entry into the project, and EBRD said the resulting legal uncertainty prevented it from progressing its financing decision.
Archive reference: SLF-2007-069
Collection: The Sakhalin Papers
Principal institutional record: European Bank for Reconstruction and Development Sakhalin II records and Independent Recourse Mechanism file
Authenticated corporate record: The Shell Sustainability Report 2006
Contemporaneous reporting: AFP, Oil & Gas Journal, RIA Novosti, The Guardian, El País
Campaign submissions: WWF, Friends of the Earth, The Corner House and Friends of the Earth Japan
Later judicial context: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Evidence standard: EBRD determinations are distinguished from campaign-group interpretations of them. Sakhalin Energy statements are attributed to the company. Russian environmental allegations are distinguished from contemporaneous claims that regulatory action was being used to influence Gazprom’s entry into the project. No court identified in this file determined that the 2006 Russian enforcement campaign was either fabricated or politically motivated.








THE SHELL LEAKS FILES: 15 SEPTEMBER 2026

























