SecProbe.io

April 20, 2012
 Via E-mail

Ms. Kandimathie Christine Ramon Chief Financial Officer Sasol Limited 1 Sturdee Avenue Rosebank 2196 South Africa
Re: Sasol Limited
 Annual Report on Form 20-F for the Fiscal Year Ended June 30, 2011
 Filed October 7, 2011  File No. 1-31615
Dear Ms. Ramon:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
    Annual Report on Form 20-F for the Fiscal Year Ended June 30, 2011

 Risk Factors, page 11

 There is a possible risk that sanctio ns may be imposed on Sasol…, page 25

 Legislation by U.S. states that may require U.S. public pension funds to divest…, page 26

 1. We note disclosure here and throughout the Form 20-F regarding contacts with Iran.
Please update us on your contacts with Iran si nce your letters to us of April 13, 2006 and
July 21, 2006, and with Syria and Sudan si nce your letter to us of March 11, 2008,
whether through subsidiaries, distributors, resellers, affiliates or other indirect
arrangements.  In this regard, we note that  your Form 20-F does not provide disclosure
about contacts with Syria and Sudan.  Please te ll us about the outcome of the feasibility

Kandimathie Christine Ramon Sasol Limited April 20, 2012 Page 2

 studies relating to a gas-to-liq uids project in Iran discu ssed in your 2006 letters and the
potential ammonia/urea project at Assaluyeh, Iran discusse d in your 2009 Form 20-F, and
tell us about the ethane cracker commissi oned at your Arya Sasol Polymer Project in
November 2007 and the low-density polyethyl ene plant and high-de nsity polyethylene
plant that reached beneficial  operation in 2009.  Please di scuss whether and how these
activities affected your disclo sure about the risk of viol ating sanctions based upon the
business you do in Iran and the pr oducts that you  produce there.
 2. As you know, Iran, Syria and Sudan are identifie d by the U.S. Department of State as
state sponsors of terrorism and are subject  to U.S. economic sanctions and export
controls.  Your response should describe any services or products you have provided to
Iran, Syria and Sudan and any agreements, comm ercial arrangements, or other contacts
you have had with the governments of these countries, or entities controlled by their
governments.  We note for instance that your Ar ya Sasol Polymer joint venture partner is
a subsidiary of the National Petrochemical Co mpany of Iran and that Natref obtains crude
oil from Naftiran Intertrade Company Li mited, which is wholly-owned by National
Iranian Oil Co.
 3. Please tell us whether any of the servi ces, products, compounds or by-products you
produce in or export to Iran, Syria or Sudan, di rectly or indirectl y, have military or
weapons applications.  Describe any such app lications made of those services, products,
compounds or by-products in or by thos e countries, of which you are aware.
 4. Please discuss the materiality of your cont acts with Syria and Sudan described in
response to the foregoing comments and whethe r those contacts constitute a material
investment risk for your security holders.  You should address mate riality in quantitative
terms, including the approximate dollar amount s of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period.  Also, address
materiality in terms of qualitative factor s that a reasonable in vestor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and sh are value.  Various state and municipal
governments, universities, and other investor s have proposed or a dopted divestment or
similar initiatives regarding investment in companies that do business with U.S.-
designated state sponsors of terrorism.  Your  materiality analysis  should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations a ssociated with Syria and Sudan.
 5. We note your disclosure about the potential fo r reputational harm from  your activities in
Iran.  Please discuss for us, with a view toward s disclosure in future filings, the potential
for reputational harm from your business relati onships with Naftiran  Intertrade Company
Limited, which was sanctioned by the U.S. government in 2010 for financing energy
projects in Iran, and with s ubsidiaries of the National Petr ochemical Company of Iran and
National Iranian Oil Co., both of which ar e on the U.S. Department of Treasury’s
Specially Designated Nationals List.

Kandimathie Christine Ramon Sasol Limited April 20, 2012 Page 3

 6. In future filings, please make clear that th e Iran Sanctions Act has been amended by the
Comprehensive Iran Sanctions, Account ability and Divestment Act of 2010.
 Note C.55 – Acquisitions, page F-162

 7. We note that in March and June 2011 you ac quired a 50% stake in Talisman Energy
Inc.’s Farrell Creek and Cypress A shale gas assets located in Canada for R14.2 billion
total, for which you paid R3.8 billion in cas h, and will settle the remainder of the
purchase consideration through capital carry obligations. Plea se expand your disclosure
to clarify the total amount recorded for the acquisitions and discuss the length and terms of your capital carry obligations . If the total value recorded for the acquisitions is not the
R14.2 billion identified as the total purchase  consideration, please explain your basis for
recording the transactions  at a lower amount.
 Engineering Comments

 Information on the Company, page 28

 Summary of natural oil and gas prove d reserves at 30 June 2011, page 129

8. We note the disclosed reserves attributed to Sasol Petroleum International.  Please amend
your document to include your synthetic o il reserves.  Refer to Items 1202(a)(1) –
1202(a)(4) of Regulation S-K.
 9. Please explain to us the source(s) for feed stock coal that is converted to synthetic oil, the
historical conversion factors for extracted coal  reserves to syntheti c oil (tonne coal/barrel
oil) and the conversion factor used to estim ate your synthetic o il reserves.  Address
whether you have reduced your disclosed coal  reserves to accomm odate synthetic oil
reserves.  We may have further comment.
 Proved undeveloped reserves converted to  proved developed reserves, page 130

 10. We note your statement, “During 2011, the cap ital expenditures made in Gabon, with the
drilling of two new wells in the Etame Mari n Permit, resulted in the conversion of 1,9
Mbbl of previously undeveloped oil reserves  to proved developed reserves.”  Please
amend your document to disclose the figures for these capital expenditures.  Refer to
Item 1203(c) of Regulation S-K.
 11. We note that you have 800 BCF of proved gas reserves that have remained undeveloped
for five years.  Rule 4-10(a)(31) (ii) of Regulati on S-X states, “
Undrilled locations can be
classified as having undeveloped reserves only if a development plan has been adopted
indicating that they are scheduled to be dr illed within five years, unless the specific
circumstances, justify a longer time.”  Please explain to us why you believe that these
volumes should be characterized as a development project rather than a drilling program.
Refer to Regulation S-X, Rules 4-10(a)(8), (a)(26), (a)(31)(ii) and Compliance and

Kandimathie Christine Ramon Sasol Limited April 20, 2012 Page 4

 Disclosure Interpretations, Questions 108.01, 131.03, 131.04 and 131.06 presented at
http://www.sec.gov/divisions/corpfin /guidance/oilandga s-interp.htm.
 Closing Comments

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing in cludes all information re quired under the Securities
Exchange Act of 1934 and that they have provi ded all information investors require for an
informed investment decision.  Since the compa ny and its management are in possession of all
facts relating to a company’s disclosure, they are responsible for the acc uracy and adequacy of
the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Ronald Winf rey, Petroleum Engineer, at (202) 551-3704 with questions
about engineering comments. You may contact Lily Dang, Staff Accountant, at (202) 551-3867
or Mark Wojciechowski, Staff Accountant, at  (202) 551-3759 if you have questions regarding
comments on the financial statements and relate d matters.  Please contact Caroline Kim, Staff
Attorney, at (202) 551-3878 or, in her absence,  Timothy Levenberg, Special Counsel, at (202)
551- 3707 with any other questions.
Sincerely,
         / s / H .  R o g e r  S c h w a l l           H .  R o g e r  S c h w a l l          A s s i s t a n t  D i r e c t o r