SecProbe.io

Mailstop 3561
December 15, 2017

Turid M. Sorensen
Chief Financial Officer
Nordic American Tankers Limited
LOM Building
27 Reid Street
Hamilton HM 11
Bermuda

Re: Nordic American Tankers Limited
 Form 20-F for Fiscal Year Ended December 31, 2016
Filed May 1, 2017
File No. 001-13944

Dear Mr. Sorensen :

We have reviewed your filing an d 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to  your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments .

General

1. We note that on June 22, 2017 and December 12, 2017 you filed on Forms 6 -K your
2017 first and third quarter earnings release s, respectively .  We also note that your
website provides an earnings release to your investors for the second quarter of 2017.
Please file your second quarter  2017  earnings release on Form 6 -K.  Refer to General
Instruction B of Form 6 -K.

Turid M. Sorensen
Nordic American Tankers Limited
December 15 , 2017
Page 2

 Form 20 -F for Fiscal Year Ended December 31, 2016

Item 3 — Key Information

D. — Risk Factors, page 4

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, which could adversely affect our reputation and the
market for our common stock, page 11

2. In your letter to us dated August 15, 2015, you described your vessels’ calls o n ports in
Sudan.   You disclose in the Form 20 -F that your vessels may, on charterers’ instructions,
call on ports in Sudan.   Sudan is identified by the U.S. Department of State as a state
sponsor of terrorism, and is subject to U.S. export controls.   You do not discuss in the
Form 20 -F contacts with Sudan.   Please describe to us the nature and extent of any past,
current and anticipated contacts with Sudan since the referenced letter, whether through
subsidiaries, charterers, or other direct or indirect ar rangements.   You should describe
any goods, services or fees you have provided into Sudan, directly or indirectly, and any
agreements, arrangements or other contacts you have had with the government of Sudan
or entities it controls.

3. Please tell us the a pproximate dollar amounts of any revenues, assets and liabilities
associated with Sudan for the last three fiscal years and the subsequent interim period.

Item 5 — Operating and Financial Review and Prospects, page 32

H. — Critical Accounting Policie s, page 39

Vessel Impairment, page 41

4. We note that your estimates of TCE use average estimated day rates provided by Marex
for the first and second year and the average 15 -year Suezmax Earnings Trend from
Clarksons for the years thereafter.   We also no te that both are adjusted to estimate the
actual TCE used to estimate the impairment of your vessels.  Please tell us and revise
your future filings to discuss the following:
 your methodology of weighting these rates, including whether you considered a
probability -weighted approach a s discussed at ASC 360 -10-35-30
 any adjustments made to your fi nal determination of actual TCE
 why you use different sources for your rates in the first and second year assumptions
as comparaed to  the years thereafter
 whether  you consider inflation in your projections for operating expenses; and
 your consideration of the possible sale of your vessels given the challenging market
and the event of default on your credit facility per ASC 360 -10-35-30.
It would be helpful if you c ould provide us with an example of your calculation of actual
TCE.

Turid M. Sorensen
Nordic American Tankers Limited
December 15 , 2017
Page 3

 Goodwill, page 43

5. We note that you have one reporting unit with goodwill attributed to it. We also note that
you performed a goodwill impairment assessment as of December 31, 2016 using an
income valuation approach and the estimated fair value of your reporting unit exceeded
its carrying value.  We note from your accounting policy on page F -13 (Goodwill) that
you use a discoun ted cash flow model to determine the fair value of a reporting unit
unless there is a readily determinable fair market value.  Further, we note that your
market capitalization was lower than the book value of stockholders’ equity at December
31, 2016.  Please respond to the following:
 Tell us and revise your future filings to disclose the percentage by which the fair
value of the reporting unit exceeded the carrying value.
 Tell us and revise your future filings to disclose the assumptions and estimates used
in step one of your goodwill impairment test  (e.g. discount rate ), include an
explanation to us of why you believe these assumptions are reasonable .
 Tell us and revise your future filings to disclose the following related to the
aforementioned key assum ptions: (i) the degree of uncertainty associated with these
key assumptions; and (ii) a sensitivity analyses that demonstrates how changes in
each key assumption would impact your estimate of the fair value of the reporting
unit.
 Please tell us why you d id not use the market approach in your valuation analysis.
Refer to ASC 350 -20-35-24.
 Provide us with a reconciliation of the aggregate fair value of your reporting unit to
your market capitalization as of December 31, 2016.
Please refer to Item 5.D of F orm 20 -F and Section V of SEC Release No. 33 -8350.

Exhibits, page 71

6. Please file as an exhibit the revolving credit facility referenced on pages 37 and F -21.
We also note that this credit facility is identified as a material contract on page 55.

Consolidated Balance Sheets as of December 31, 2016 and 2015, page F -6

7. We note from your disclosure on page F -21 (Credit Facility) that you are in default with a
debt covenant under your credit facility (i.e., the security covenant ratio).  In light of th is
default, your creditor has provided you with a waiver which lowers the requirements
under this ratio until May 31, 2018.  Please respond to the following:
 Tell us how you considered whether or not this credit facility should be classified as a
current l iability.  Refer to ASC 470 -10-45-11 for guidance and ASC 470 -10-55-2 for
an illustration .
 Separately, tell us and revise future filings to disclose whether or not this debt is
currently callable by your lenders , and if not;  explain to us and disclose in future
filings the circumstances which would allow your lenders to call this debt.

Turid M. Sorensen
Nordic American Tankers Limited
December 15 , 2017
Page 4

 8. Additionally, given the default on your debt covenant and the material weakness related
to the application of ASU 2014 -15, please tell us your consi deration to provide
disclosures pursuant to ASC 205 -40-50-12.  We note that default on a loan is an example
of an adverse condition and event that may raise substantial doubt about an entity’s
ability to continue as a going concern per ASC 205 -40-55-2.  If  you concluded that the
default and/or other adverse conditions and events did not raise to the level of substantial
doubt, then please provide us with your analysis that led to this conclusion and cite any
relevant guidance considered.

We remind you th at the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Jim Dunn  at (202) 551 -3724 or me at (202) 551 -3379 if you have
questions regarding comments on the financial statements and related matters.  Please contact
John Stickle  at (202) 551 -3324 or John D. Brown  at (202) 551 -3859 with any other questions.

Sincerely,

 /s/ Melissa Raminpour

Melissa Raminpour
Branch Chief
Office of Transportation and Leisure