SEC Comment Letter for PETROBRAS - PETROLEO BRASILEIRO SA (PBR, PBR-A) (CIK 0001119639) (PBR) — Jul 14, 2020
PETROBRAS - PETROLEO BRASILEIRO SA (PBR, PBR-A) (CIK 0001119639)
Date: July 14, 2020 · CIK: 0001119639 · Accession: 0000000000-20-006402
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File numbers found in text: 333-239714
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United States securities and exchange commission logo
July 14, 2020
Andrea Marques de Almeida
Chief Financial Officer and Chief Investor Relations Officer
Petróleo Brasileiro S.A. – Petrobras
Avenida Republica do Chile, 65—23rd Floor
20031-912—Rio de Janeiro—RJ—Brazil
Re:Petróleo Brasileiro S.A. – Petrobras
Registration Statement on Form F-4
Filed July 6, 2020
File No. 333-239714
Dear Ms. Almeida:
We have limited our review of your registration statement to those issues we have
addressed in our 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 by amending your registration statement and providing the
requested information. If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Form F-4 filed July 6, 2020
Exhibits
1.Please file the articles of association for co-registrant Petrobras Global Finance B.V. as
currently in effect, along with any amendments. See Item 601(b)(3)(i) of Regulation S-K.
General
2.Please be advised that we will not be in a position to accelerate the effectiveness of your
registration statement until our comments relating to the Form 20-F filed by Petróleo
Brasileiro S.A.—Petrobras for the fiscal year ended December 31, 2019 have been
resolved.
FirstName LastNameAndrea Marques de Almeida
Comapany NamePetróleo Brasileiro S.A. – Petrobras
July 14, 2020 Page 2
FirstName LastName
Andrea Marques de Almeida
Petróleo Brasileiro S.A. – Petrobras
July 14, 2020
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.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
Please contact Kevin Dougherty, Staff Attorney, at (202) 551-3271 or in his absence,
Timothy S. Levenberg, Special Counsel, at (202) 551-3707 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc: Francesca L. Odell