
THE SHELL LEAKS FILES — 21 OCTOBER 2026
SLF-2007-094
The Sakhalin Papers LXXXIV: The Foreseeability Test — What Shell and Its Partners Knew Before the Nord Stream 2 Investment Was Written Off
Shell’s own records establish that its final Nord Stream 2 loan instalments were made in the second quarter of 2020. By then, European legislation had changed, the project was facing legal challenges, American sanctions had disrupted construction and Germany’s energy regulator was deciding whether the pipeline qualified for an exemption. A subsequent European court judgment raises an important question: how much of this risk was foreseeable?
Archive reference: SLF-2007-094
Publication date: 21 October 2026
Collection: The Sakhalin Papers — Shell, Gazprom and Russia
Previous instalment: SLF-2007-093, The Sakhalin Papers LXXXIII, 20 October 2026
Principal sources: Shell’s 24 April 2017 financing announcement; Shell’s published 2022 financial results; European Parliament proceedings; European Commission and Council records; the German Federal Network Agency’s May 2020 decision; the EU General Court’s November 2024 judgment; Allseas’ December 2019 statement; and contemporaneous Reuters reporting.
Evidence classification: Authenticated corporate disclosures, official legislative and regulatory records, judicial findings, contemporaneous journalism and separately identified editorial analysis.
Editorial illustration accompanying a review of Shell-related U.S. and Australian court records.





























