SEC Comment Letter 0000000000-23-007736 to EURO TECH HOLDINGS CO LTD (CLWT) (CIK 0001026662) (CLWT)
EURO TECH HOLDINGS CO LTD (CLWT) (CIK 0001026662)
Date: July 20, 2023 · CIK: 0001026662 · Accession: 0000000000-23-007736
AI Filing Summary & Sentiment
File numbers found in text: 000-22113
Letter
United States securities and exchange commission logo July 20, 2023 David Leung Chief Executive Officer Euro Tech Holdings Company Limited Unit D, 18/F, Gee Chang Hong Centre 65 Wong Chuk Hang Road Hong Kong Re:Euro Tech Holdings Company Limited Form 20-F for the Fiscal Year Ended December 31, 2022 File No. 000-22113 Dear David Leung: We have limited our review of your filing to the submission and/or disclosures as required by Item 16I of Form 20-F and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. After reviewing your response to this comment, we may have additional comments. Form 20-F for the Fiscal Year Ended December 31, 2022 General 1.We note that during your fiscal year 2022 you were identified by the Commission pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C. 7214(i)(2)(A)) as having retained, for the preparation of the audit report on your financial statements included in the Form 20-F, a registered public accounting firm that has a branch or office that is located in a foreign jurisdiction and that the Public Company Accounting Oversight Board had determined it is unable to inspect or investigate completely because of a position taken by an authority in the foreign jurisdiction. Please provide the documentation required by Item 16I(a) of Form 20-F or tell us why you are not required to do so. Additionally, please amend your Form 20-F to provide the disclosures required under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the Holding Foreign Companies Accountable Act and the Consolidated Appropriations Act, 2023, available on our website at https://www.sec.gov/corpfin/announcement/statement- hfcaa-040623.
FirstName LastNameDavid Leung Comapany NameEuro Tech Holdings Company Limited July 20, 2023 Page 2 FirstName LastName David Leung Euro Tech Holdings Company Limited July 20, 2023 Page 2 We remind you that 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. Please contact Tyler Howes at 202-551-3370 or Christopher Dunham at 202-551-3783 with any questions. Sincerely, Division of Corporation Finance cc: Richard Friedman, Esq.
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United States securities and exchange commission logo
July 20, 2023
David Leung
Chief Executive Officer
Euro Tech Holdings Company Limited
Unit D, 18/F, Gee Chang Hong Centre
65 Wong Chuk Hang Road
Hong Kong
Re:Euro Tech Holdings Company Limited
Form 20-F for the Fiscal Year Ended December 31, 2022
File No. 000-22113
Dear David Leung:
We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and have the following comment. In our comment, we may
ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.
After reviewing your response to this comment, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
General
1.We note that during your fiscal year 2022 you were identified by the Commission
pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C.
7214(i)(2)(A)) as having retained, for the preparation of the audit report on your financial
statements included in the Form 20-F, a registered public accounting firm that has a
branch or office that is located in a foreign jurisdiction and that the Public Company
Accounting Oversight Board had determined it is unable to inspect or investigate
completely because of a position taken by an authority in the foreign jurisdiction. Please
provide the documentation required by Item 16I(a) of Form 20-F or tell us why you are
not required to do so. Additionally, please amend your Form 20-F to provide the
disclosures required under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the
Holding Foreign Companies Accountable Act and the Consolidated Appropriations Act,
2023, available on our website at https://www.sec.gov/corpfin/announcement/statement-
hfcaa-040623.
FirstName LastNameDavid Leung
Comapany NameEuro Tech Holdings Company Limited
July 20, 2023 Page 2
FirstName LastName
David Leung
Euro Tech Holdings Company Limited
July 20, 2023
Page 2
We remind you that 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.
Please contact Tyler Howes at 202-551-3370 or Christopher Dunham at 202-551-3783
with any questions.
Sincerely,
Division of Corporation Finance
cc: Richard Friedman, Esq.