Nord Stream 2 – Entrenching Putin’s Economic and Political Corruption

Nord Stream 2 – Entrenching Putin’s Economic and Political Corruption

The traumatic exit of the US military from Kabul has removed covers from an elephant in the room that most western policy makers had an inkling about for a long while. Rabid corruption in Afghanistan has made all wishful thinking about democratic transition in this country futile from the outset. It is something that western policy-makers should have started speaking about openly and loudly years ago, not now.

We should be prepared to face a similar revelation and rude awakening with the Nord Stream 2 pipeline—an utterly corrupt gas export project doggedly pushed through by the Kremlin—as soon as it becomes operational.

This brief aims to highlight in concrete and unequivocal ways in which Nord Stream 2 has already spurred grave economic and political corruption in Russia and Europe and will undoubtedly continue to do so on an even grander scale once the project is operational. This is something that, as with Afghanistan’s corruption, is already intuitively understood in most circles in Washington D.C. and Brussels but continues to be swept under the rug in pursuit of “normal” relations with the Kremlin and allies in Germany.

NS2 Grand Corruption

Critical analysis of corruption surrounding Gazprom its Nord Stream 2 has been met with vicious pushback from Russia even targeting its most loyal commentators. In May 2018, analysts from Sberbank CIB, Alex Fak and Anna Kotelnikova, published research on the Russian oil and gas industry. The head of Sberbank, German Gref, fired Fak for the research and apologized to Gennady Timchenko and Arkady Rotenberg – Putin`s cronies named as beneficiaries of the Gazprom pipeline construction strategy by the report.[i] The main points from the Sberbank CIB research were the following:

A. Gazprom`s investment program can best be understood as a way to employ the company`s entrenched contractors at the expense of shareholders. The three major projects that will eat up half of the capex in the next five years – Power of Siberia, Nord Stream 2 and Turkish Stream – are deeply value-destructive.

B. It is commonly believed that the Russian government has been forcing Gazprom to construct the major routes to bypass Ukraine —Turkish Stream and Nord Stream 2. Because they reach no new markets, these routes entail no marginal revenue whatsoever. Whatever benefit they derive comes from savings on transit costs, but their main rationale is a geopolitical one – to bypass the existing Ukrainian system.

NS1 and NS2 – Entrenched Corrupt Networks and Methods

Arkady and Boris Rotenberg and Gennady Timchenko

Corruption stories surrounding Nord Stream 1 and 2, Gazprom, and Putin’s inner circle demonstrate that the more money the Kremlin gets, the greater is the retreat of democracy in Russia and in Europe.  To better understand value destruction rendered by Gazrpom, the US public should be informed that both Nord Stream 1 and 2 have been implemented at a direct loss to the Russian budget, taxpayers and the environment, and the damage will continue to grow.

Putin’s insiders Arkady and Boris Rotenberg, along with Gennady Timchenko, are the main beneficiaries of Nord Stream 1 in Russia. Between 2003 and 2006, firms of the Rotenberg brothers functioned as artificial intermediaries in the sale of the trunk pipeline from the Chelyabinsk pipeline plant to Gazprom. In 2007, they opened the Nord Stream Pipeline Project company, which became the main intermediary for the re-sale of pipelines for Nord Stream 1, bringing around $1bn of profit between 2008 and 2012. Eventually, Russia’s Anti-Monopoly Agency acted against this scheme, but only after the construction and money transfer for Nord Stream 1 had been finished.[ii] Essentially, this means that Rotenberg brothers got away with the funds, and the Anti-Monopoly Agency late interference was just for show. Sberbank CIB report mentions Rotenberg-controlled company StroyGazMontazh (STM) as a key beneficiary of Nord Stream 2 construction process.[iii]

Gennady Timchenko, Putin’s partner and friend from early 1990s, gained control over StroyTransGas (STG) and StroyTransNefteGaz (STNG) at deflated price from Gazprom in 2007-13, as did Rotenberg brothers when they bought STM from the monopoly in 2008 which experts Boris Nemtsov and Vladimir Milov considered evidence of corruption.[iv] These three companies then received lucrative contracts to complete onshore work for Nord Stream 1[v] and 2[vi] and pipeline work for connection with future distribution network of Nord Stream 1 and 2 in Czech Republic. STG and STNG were also cited by Sberbank CIB report along with STM as benefiting from Nord Stream 2 contracts while Gazprom tried to hide some of their involvement with the project.[vii]

Timchenko also has acquired multiple other assets previously owned by Gazprom[viii] through his stake in Bank Rossiya, Novatek and other entities closely associated with Putin’s inner circle (see more on this in the section on Kirill Shamalov). According to Nemtsov and Milov, these cronies of Putin and firms that they control gained billions of dollars from these insider deals with Gazprom.[ix]

Timchenko and the Rotenberg brothers, sanctioned by the US Treasury for their involvement in Russia’s war against Ukraine,[x] continue to benefit heavily from Gazprom’s murky schemes in the production and transportation of gas, including for Nord Stream 1 and 2 and associated $35 billion expansion of onshore gas pipeline network all the way from Yamal Peninsula to the Baltic Sea,[xi] even though they have been more careful to cover up their insider relations with offshore Nord Stream 2 development.

Aslan Gagiyev, Gennadiy Petrov and Igor Yusufov

Between 2008-2016, top Russian officials (including the head of the Moscow Nord Stream 1 office) and mafia bosses, bought and controlled Nordic Yards, a shipbuilding dock in Angela Merkel’s electoral district in East Pomerania, where they ran money-laundering and other corruption schemes.[xii] One of the shadow co-owners, Aslan Gagiyev, was extradited by Austrian court to Moscow in 2018[xiii] and is now being tried in Russia for over 60 murders, including related to the Yards, while the other mafia boss, Gennadiy Petrov, is a top fugitive from Spanish courts[xiv] residing in total safety in his own luxury palace in St. Petersburg with the protection from Russian government.

As western audits and police reports later showed, Igor Yusufov was involved in this criminal scheme as a shadowy partner and was one of the key officials who had control over the asset and money laundering around it. Yusufov is an insider of Putin’s circle who was previously minister of energy (2001-04), the president’s special envoy for international energy cooperation, and a Gazprom board member. He and his son Vitaly Yusufov, the then head of the Nord Stream 1 office in Moscow, hid their involvement with the asset until 2009 and later denied any corruption or criminal links with gangsters.

Alexey Miller

Alexey Miller, sanctioned by US Treasury for involvement in worldwide malign activity,[xv] has been implicated in various corruption stories long before he became CEO of Gazprom, including in the corrupt incident involving the port of St. Petersburg in late 1990s.[xvi] In 2001 and soon after becoming CEO, Miller carried out his first major aggressive corporate raiding campaign when Gazprom, at the instigation of Putin, gained control over the privately-owned petrochemical company Sibur. In the following years, Gazprom, using similar “administrative leverage” (i.e. the backing of Putin’s security services, law enforcement and courts), gained control over many gas industry assets: Vostokgazprom, Zapsibgazprom, Nortgaz, and many others, often at prices much lower than the market price. Miller was instrumental in passing control stakes in SOGAZ and other multiple subsidiaries under control of Putin’s cronies in Bank Rossiya.

Since 2005 the minority shareholders of Yukos have filed multiple lawsuits against Miller and Gazprom for illegally nationalizing parts of the company. In recent years, the Court of Arbitration of The Hague satisfied some of these claims, and as a result Gazprom announced the threat of seizure of its assets.

Kirill Shamalov

There have been numerous cases where Miller allowed Gazprom to buy and sell assets at a great financial loss to the company, including Gazprom Neftekhim Salavat (GNS), Transinvestgaz, Sibneft, and many others.[xvii] The most notorious story of enriching Putin’s insiders with such price manipulation and controversial loans has been the gradual transfer of a stake of over 20% in Sibur to Putin’s son-in-law, Kirill Shamalov, through another Putin crony, Gennady Timchenko (mentioned above). In 2018 Kirill Shamalov was sanctioned by US Treasury for involvement in worldwide malign activity.[xviii]

Shamalov, his father, as well as Timchenko, have been Putin’s closest associates, and they have received numerous lucrative assets and contracts from Gazprom and other state companies in Russia and are beneficiaries of some of the projects surrounding the expansion of the Russian gas system for Nord Stream 1 and 2.


If one looks at Gazprom’s Board of Directors or Management, it requires considerable effort to find a single top manager who is not implicated in any major corruption scandal:

1. Viktor Zubkov, Chairman of the Board: Zubkov has been partner of Vladimir Putin’s criminal schemes ever since their joint work in the mayor’s office in St. Petersburg in 1990s. Zubkov’s son-in-law Anatoliy Serdyukov has been dismissed from the position of defense minister due to overwhelming corruption cases in his ministry while Zubkov was prime minister of Russia. Spanish prosecutor’s office when dealing with the Russian mafia case in Spain, has called Zubkov mediator for Russian criminal bosses.[xix]

2. Andrey Akimov, Board member: in 2003 through his control of Gazprombank he created the Centrex group of companies, which engaged in controversial gas sales in Europe. In 2005 the European Commission noted that managers of Centrex had inappropriate close business relations with the Gazprom management.[xx] After the Panama Papers were leaked, Swiss authorities banned Gazprombank from attracting new clients for its money-laundering operations, including with Putin’s friend and cello player Sergey Roldugin.[xxi] In Cyprus, Akimov managed to extract 2 million euros from Laiki bank just 9 days before the authorities froze the bankrupt bank.[xxii]

In 2018 Akimov was sanctioned by US Treasury for involvement in worldwide malign activity.[xxiii]

3. Denis Manturov, Board Member: one of the conspicuously wealthy Russian ministers was observed practicing insider contracts during his previous role as director of a helicopter plant.[xxiv] He has also been described as a protégé of Putin’s friend Sergey Chemezov, CEO of Rostec Corporation, and involved in many controversial businesses in the defense sector.

4. Dmitry Patrushev, former Board Member: Son of Putin’s close KGB associate Nikolay Patrushev, Dmitry was appointed to manage Rosselkhozbank, a key state agricultural bank.[xxv] Under his leadership the bank lost several billion dollars, including in deals with partners of his father, but the bank was compensated at the expense of the Russian budget.[xxvi]

5. Mikhail Putin, Management Committee Member: Vladimir Putin’s cousin came to Gazprom through nepotism.[xxvii] For many years he was a key figure in SOGAZ, an insurance company run by Putin’s confidants which has benefited from multiple insider deals.

6. Kirill Seleznev, former Management Committee Member: Seleznev worked for Miller in St. Petersburg’s port where a lot of corruption scandals took place. He oversaw insider deals on condensate trade between Kazakhstan and Gazprom that benefited unnecessary intermediaries with $4 billion.[xxviii] He was also seen as the main insider in corrupt transactions around Gazenergoprombank.[xxix] In 2019 Seleznev stepped down from Gazprom soon after the arrests of his advisor Raul Arashukov and his son, corrupt senator, Rauf Arashukov who were accused of being involved in the murky gas trade in the Russian Caucasus. Seleznev remains closely involved with Russian gas distribution and export projects run by Kremlin insiders.

Gazprom, NS2 and the Environment

Green policy and environmental concerns seem to be now at the forefront of western policymakers on both sides of the Atlantic, especially in Germany and the US, this is why it is imperative to emphasize that Nord Stream 2 has brought about multiple corruption problems related to climate change and natural environment on top of massive economic and political corruption. Activity of Nord Stream 2 AG and its patron Gazprom has a devastating impact on greenhouse emissions, Baltic Sea nature, and indigenous people.[xxx]

Despite two decades of futile promises from the President of Russia, Vladimir Putin, and Gazprom to tackle the problem of gas flaring, Russian monopoly has been among top world emitters of methane, according to the World Bank data. Latest report shows that Russia tops the list of global gas flaring countries in 2020, contributing to 15 percent of global gas flaring, while Gazprom’s highly advertised new region of production in Yamal that is supposed to feed Nord Stream 2 has seen consistent rise in flaring.[xxxi]

Flaring is not simply an issue of negligence but a deliberate corrupt choice, as Gazprom’s wasteful and predatory but lucrative monopoly policy is based on denying third party access to domestic and export pipelines to more efficient gas producers. Gazprom’s poor maintenance of pipelines and associated high methane leaks are equally corrupt and inefficient.

On the territory of Russia, the Nord Stream 2 gas pipeline passes through the high-value natural area called Kurgalsky Nature Reserve which has now become a place of environmental catastrophe because of Gazprom.[xxxii] Evgeniya Chirikova, an environmental activist from Russia, conducted a special survey of violations that Nord Stream 2 has inflicted on the Kurgalsky reserve. According to her research and interviews with individuals from multiple environmental NGOs, the chosen pipeline route is extremely destructive for nature and violates several domestic and international laws.

Important information about the significance of the Kurgalsky Nature Reserve is hidden in Environmental Impact Assessment reports of Nord Stream 2 AG, also known as Espoo (Espoo reports document potential transboundary impacts of the project on nature). The regime of the Kurgalsky reserve is not reflected in the Espoo materials and other materials justifying the choice of the pipeline route. The Espoo materials are in violation of multiple laws and regulations, both domestic and international, such as Article 4 of the Convention on Environmental Impact Assessment in a Transboundary Context (the Espoo Convention) and the Ramsar Convention on Wetlands. The Espoo materials present unreliable data about the choice of the route with respect to conservation of marine mammals and birds.

The Nord Stream 2 AG company’s website has several statements that can safely be called false or misleading. In the section about Nord Stream 2 in Kurgalsky reserve the site states, “Nord Stream 2 will be implemented in accordance with Russian and international legislation.” This statement is a lie, since the Nord Stream 2 project violates several international conventions: the Ramsar Convention on Wetlands of International Importance, the Convention on the Conservation of Migratory Species of Wild Animals, and the Helsinki Convention on the Protection of the Marine Environment of the Baltic Sea Area. Additionally, construction of the Nord Stream 2 pipeline is in violation of the Russian Federal Laws “On Wildlife” and “On Specially Protected Natural Territories”.[xxxiii] 

Greenpeace Austria has received secret minutes of meetings between Russian government members and representatives of Nord Stream 2 AG and Gazprom from a former high-ranking official of the Russian Ministry of the Environment, which discussed the changes in environmental legislation or the boundaries of Kurgalsky Nature Reserve for the implementation of the Nord Stream 2 project.[xxxiv]

Gazprom also manipulated public hearings, which are supposed to be an integral part of any genuine due process but were carried out fraudulently by Gazprom. Contrary to what the Nord Stream 2 AG and local officials argue, residents that attended public meetings did not express support for the Nord Stream 2 project.[xxxv]

Some residents in the Kurgalsky region identify themselves as indigenous people: Izhora, Ingermanlanders, and Vod. According to the ILO 169 (The Indigenous and Tribal Peoples Convention, 1989 is an International Labour Organization Convention, also known as ILO-convention 169) standards, these people fall under the protection of Free Prior and Informed Consent (FPIC). As these people were not properly informed, nor consulted with, FPIC was not implemented. Residents of 18 villages of Kingiseppsky district in the Leningrad region addressed the President of Russia. In their public letter they asked to stop construction of the Nord Stream 2 pipeline and spare the Kurgalsky reserve but to no avail.

The bottom line from all these pieces of evidence is that Gazprom and Nord Stream 2 AG are not shy to manipulate and forge environmental documents, fizzle out rule of environmental laws and regulations and tramp over key international agreements related to the protection of nature.

Price of Inaction

International and Russian media and activists —among them the late Boris Nemtsov and current opposition leaders Alexey Navalny and Vladimir Milov —have uncovered numerous other corruption schemes .[xxxvi] These include illegal expropriation of Gazprom’s assets and cashflows by Putin’s insiders, construction of palaces and acquisition of luxury property by Gazprom associates, influence operations in the West by Nord Stream 1 and 2 and other Gazprom-controlled entities.

Despite the substantial evidence publicized by these investigations, Western policymakers and corporations refuse to fully appreciate the grave implications of corruption that has accompanied the construction of Nord Stream 1 and Gazprom’s and is now clearly linked to Nord Stream 2. Here is a list of the most common schemes used by Gazprom, which is far from exhaustive, but could be likely transplanted further in European jurisdictions:

  • Opaque procurement processes and employment of unnecessary expensive intermediaries
  • Using connections with organized criminal groups and money laundering in Europe to advance deals and acquire distressed assets
  • Manipulating regional and country markets and energy pricing, insisting on bilateral opaque deals that circumvent western sanctions and EU regulations on market transparency and competition
  • Spreading malign propaganda against renewable energy and climate change policies, forging or manipulating documentation on environmental protection
  • Coopting senior politicians and corporate figures/entities in Gazprom’s network in Europe through excessive salaries and other incentives

Gazprom’s corruption, including through its operations via Nord Stream 1 and 2 and other export channels in Europe, have shown a consistent track record of poor governance and outright criminality. A careful observer of Gazprom’s activity in Europe over the last two decades will have to come to the conclusion that the monopoly’s unabetted operations through Nord Stream 2 will bring even more of Kremlin-supported corruption into Europe, destroying democratic societies and institutions.

U.S. and EU Responses

Most European policy-makers are now aware of the problems posed by Gazprom’s opaque methods and inquiries into Gazprom’s corrupt strategy have been made at highest ranks of the EU. In 2011, an antitrust investigation against Gazprom was initiated in eight EU countries. In 2015, the European Commission filed charges and denounced Gazprom for the illegal partitioning of EU markets, denying third-party access to gas pipelines, and unlawful pricing, all of which aimed at politically and economically strangling Central and Eastern European countries.

In 2018, Gazprom, however, made a deal with the EU on the outcome of the investigation without incurring hefty fines by promising a reformed approach.[xxxvii] Thusly, Gazprom’s past corrupt behavior was swept under the rug for political reasons, namely, to appease the Kremlin. Many EU members still saw the deal as too lenient on Gazprom.

Since then, the U.S. and EU have placed Gazprom, Gazprombank and multiple other affiliate companies on sanctions lists that are supposed to limit their ability to raise long-term capital in the West and gain access to new advanced technology for upstream production. Even though Gazprom and its subsidiaries lost access to some of the traditional loan mechanisms from international banks, they are still receiving lucrative hard currency cashflows from gas exports and are free to use European bond markets. Just this year, Gazprombank has raised billions of dollars in U.S. dollar issue Eurobonds, including from U.S. investors who found ongoing sanctions against Nord Stream 2 toothless.[xxxviii] Gazprom has abandoned some of its more technically advanced offshore projects (mainly because of the downturn in global energy prices and the general economic downturn, not so much due to U.S. sanctions) but had no trouble getting all necessary technology for its ongoing projects, including for Nord Stream 2.

The U.S. Treasury has slowly sanctioned some but not all vessels (for some only prohibited US companies to cooperate with them)[xxxix] that help Gazprom complete Nord Stream 2 pipeline, but stopped short of sanctioning all shipping companies and port infrastructure entities (Russian and western) involved in the final stages of the project. U.S. administration also has kept key waivers that allow Nord Stream 2 AG to complete the pipeline.[xl]

Individual sanctions targeting key Gazprom figures have restricted their travel to the West (reportedly, this is the case with Timchenko, Rotenberg brothers and few other figures). However, it is well known, that these and other sanctioned oligarchs have regularly circumvented western sanctions by transferring their assets to relatives and other non-sanctioned insiders, forcing the U.S. Treasury to play a protracted and reactive cat-and-mouse game of chasing newly evolving circumvention schemes.[xli] Just recently, a bi-partisan Congressional investigation has uncovered that Rotenberg family successfully used largely unregulated U.S. art industry to circumvent sanctions.[xlii]

Given the ways Gazprom and its proxies brazenly use corruption and circumvent sanctions, the US Congress must act to:

  • Sanction all relevant Kremlin-connected oligarchs under existing mechanisms, such as Countering America’s Adversaries Through Sanctions Act (CAATSA) and Global Magnitsky Act (GMA)
  • Enact full weight of mandatory sanctions as prescribed by the Congress under Protecting Europe’s Energy Security Act (PEESA) and Protecting Europe’s Energy Security Clarification Act (PEESCA), such removing waivers for Nord Stream 2 AG and its CEO Mattias Warnig[xliii]

[i] https://www.vedomosti.ru/finance/articles/2018/05/24/770650-uvolennii-analitik-cib-kritiku-grefa

[ii] https://www.4freerussia.org/wp-content/uploads/2017/10/Corruption-Pipeline-web.pdf p.7

[iii] https://www.vedomosti.ru/economics/articles/2018/05/23/770451-uvolen-posle-obzora-pro-gazprom

[iv] https://www.putin-itogi.ru/putin-corruption-an-independent-white-paper/

[v] http://www.stg.ru/ru/press-centr/dokumentyi-foto-i-videomaterialyi/foto/nord-stream.html

[vi] https://www.interfax.ru/business/625840

[vii] https://www.youtube.com/watch?v=ZMmFI7hqcF4

[viii] https://www.4freerussia.org/wp-content/uploads/sites/3/2018/05/Putin2018_US_web.pdf p.43

[ix] https://www.putin-itogi.ru/putin-corruption-an-independent-white-paper

[x] https://www.treasury.gov/press-center/press-releases/Pages/jl23331.aspx

[xi] https://rethinkthedeal.4freerussia.org/wp-content/uploads/sites/4/2019/10/Brochure-A4-Germany-EN-Web.pdf pp. 20-21

[xii] https://www.4freerussia.org/wp-content/uploads/sites/3/2019/06/MisruleOfLaw-Web.pdf pp. 23-26

[xiii] https://www.occrp.org/en/28-ccwatch/cc-watch-indepth/8539-the-brotherhood-of-killers-and-cops

[xiv] https://www.theatlantic.com/international/archive/2017/11/russian-mob-mallorca-spain/545504/

[xv] https://home.treasury.gov/news/featured-stories/treasury-designates-russian-oligarchs-officials-and-entities-in-response-to-worldwide-malign-activity

[xvi] https://www.underminers.info/publications/2018/7/15/profile-alexey-miller; https://www.4freerussia.org/wp-content/uploads/2017/10/Corruption-Pipeline-web.pdf pp. 5-6

[xvii] https://www.reuters.com/investigates/special-report/russia-capitalism-shamalov; https://www.theguardian.com/world/2016/feb/25/putins-alleged-son-in-law-in-top-10-list-of-russian-state-contract-winners

[xviii] https://home.treasury.gov/news/featured-stories/treasury-designates-russian-oligarchs-officials-and-entities-in-response-to-worldwide-malign-activity

[xix] https://newtimes.ru/articles/detail/148113/

[xx] https://www.forbes.ru/forbes/issue/2015-04/283037-bankir-pod-prikrytiem

[xxi] https://www.finma.ch/en/news/2018/02/20180201-mm-gazprombank-schweiz/; https://krug.novayagazeta.ru/12-zoloto-partituri

[xxii] https://www.gazeta.ru/business/2013/04/03/5242401.shtml

[xxiii] https://home.treasury.gov/news/press-releases/sm0338

[xxiv] https://www.svoboda.org/a/27850315.html

[xxv] https://novayagazeta.ru/articles/2018/05/18/76515-patrusheva-otpravili-na-kartoshku

[xxvi] https://sobesednik.ru/politika/20180213-molodoj-da-blatnoj-ili-novyj-dvoryanin-dmitrij-patrushev

[xxvii] https://www.bbc.com/russian/features-49019951

[xxviii] https://novayagazeta.ru/articles/2016/03/02/67629-kondensat-milliardov

[xxix] https://novayagazeta.ru/articles/2016/02/28/67588-171-gazprom-187-sbyvaet-mechty

[xxx] https://rethinkthedeal.4freerussia.org/wp-content/uploads/sites/4/2019/09/RethinkTheDeal-EN.pdf pp.4-11

[xxxi] https://thedocs.worldbank.org/en/doc/1f7221545bf1b7c89b850dd85cb409b0-0400072021/original/WB-GGFR-Report-Design-05a.pdf

[xxxii] https://ccb.se/savekurgalskiy

[xxxiii] https://media.greenpeace.org/archive/Illegal-Construction-of-Nord-Stream-2-Pipeline-in-Russia—Clipreel-27MZIFJJJNB8T.html; https://www.greenpeace.org/international/story/11830/gazprom-wants-to-build-a-gas-pipeline-through-a-unique-nature-reserve/

[xxxiv] https://democratic-europe.eu/2019/12/28/hypocrisy-and-double-standards-of-the-nord-stream-2-project/; https://docplayer.org/48370135-Geheimakte-nord-stream-2.html

[xxxv] https://www.ccb.se/Evidence2017/NS2/Protokol_Espoo_public_Kingisepp.pdf

[xxxvi] https://www.putin-itogi.ru/putin-corruption-an-independent-white-paper/; https://www.putin-itogi.ru/kommunalnye-tarify-putin-i-gazprom/; https://www.youtube.com/watch?v=KejGTmnev18; https://www.youtube.com/watch?v=ZMmFI7hqcF4; https://www.youtube.com/watch?v=Ox2w5-sFkN4

[xxxvii] https://www.reuters.com/article/us-eu-gazprom-antitrust/eu-ends-antitrust-case-against-gazprom-without-fines-idUSKCN1IP1IV

[xxxviii] https://www.reuters.com/article/gazprom-eurobond/update-3-investors-buy-2-bln-in-gazprom-eurobond-shrugging-off-nord-stream-2-sanctions-idUSL1N2JV0OA

[xxxix] https://www.argusmedia.com/en/news/2217764-us-details-sanctions-against-nord-stream-2-ships

[xl] https://www.reuters.com/world/us-issues-nord-stream-2-related-sanctions-russians-blinken-2021-08-20/

[xli] https://www.treasury.gov/press-center/press-releases/Pages/jl0314.aspx

[xlii] https://www.politico.com/news/2020/07/29/probe-russian-oligarchs-evade-art-sanctions-386154

[xliii] https://www.ukrweekly.com/uwwp/in-letter-to-blinken-house-foreign-affairs-committee-urges-immediate-removal-of-nord-stream-2-sanctions-waivers/

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