SEC Comment Letter for NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177) (NAT) — Aug 7, 2014
NORDIC AMERICAN TANKERS Ltd (NAT) (CIK 0001000177)
Date: Aug. 7, 2014 · CIK: 0001000177 · Accession: 0000000000-14-040049
AI Filing Summary & Sentiment
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
August 7, 2014
Via E -mail
Turid M. Sørensen
Chief Financial Officer and Executive Vice President
Nordic American Tankers Limited
LOM Building
27 Reid Street
Hamilton HM 11
Bermuda
Re: Nordic American Tankers Limited
Form 20 -F for the Fiscal Year Ended December 31, 2013
Filed April 4, 2014
File No. 1 -13944
Dear Ms. Sørensen :
We have limited our review of your filing to your contacts with a country that has been
identified as a state sponsor of terrorism, and we have the following comments. Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues. In our comments we ask you to provi de us with information so we may better
understand your disclosure.
Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comments, we may
have additional comments.
From time to time, our vessels call on ports located in countries that are subject to restrictions
imposed by the U.S. or other governments, that could adversely affect our reputation and the
market for our common stock , page 9 .
1. You indicate that vessels in your fleet called on ports in Sudan during 2013. As you
know, Sudan is designated as a state sponsor of terrorism by the U.S. Department of State
and is subject to U.S. economic sanctions and export controls. You do not describe your
conta cts with Sudan in the Form 20 -F. Please provide us with information regarding
your contacts with Sudan since your letter to us dated August 11, 2011. You should
describe any goods, services or fees you have provided into Sudan, directly and
indirectly, and any agreements , arrangements or other contacts you have had with th e
government of Sudan .
Turid M. Sørensen
Nordic American Tankers Limited
August 7, 2014
Page 2
2. Please tell us the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan for the last three fiscal years and the subsequent interim period .
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the compa ny and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the c ompany
acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.
Please contact Pradip Bhaumik, Special Counsel, at (202) 551-3333 or me at (202) 551 -
3470 if you have any questions about the comments or our review.
Sincerely,
/s/ Cecilia Blye
Cecilia Blye, Chief
Office of Global Security Risk
cc: Max Webb
Assistant Director
Division of Corporatio n Finance