THE SHELL LEAKS FILES — 23 OCTOBER 2026
SLF-2007-096
The Sakhalin Papers LXXXVI: The Grandfathering Gamble — How Washington Changed the Rules for Nord Stream 2’s European Financiers
On 15 July 2020, the United States removed a crucial protection previously afforded to financing agreements signed before August 2017. Shell and four European energy companies had entered their Nord Stream 2 agreements in April 2017. The original American guidance had appeared to place those agreements outside the intended sanctions regime. Three years later, Washington changed its approach. The authenticated US government notice, Shell’s financial disclosures, Uniper’s contemporary warnings and a revealing statement from Wintershall Dea show how a major international financing arrangement became entangled in an escalating dispute between Washington and Europe.
Archive reference: SLF-2007-096
Publication date: 23 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-095, The Sakhalin Papers LXXXV, 22 October 2026
Principal sources: Royal Dutch Shell’s April 2017 financing announcement; the Countering America’s Adversaries Through Sanctions Act of 2017; US Department of State guidance effective 15 July 2020 and published in the Federal Register on 23 July 2020; Uniper’s 2020 Half-Year Interim Report; Wintershall Dea’s 2020 Annual Report; Shell’s 2022 financial disclosures; contemporaneous Reuters reporting; the European External Action Service’s statement of 17 July 2020; and the European General Court’s judgment of 27 November 2024.
