SEC Comment Letter for FLUOR CORP (FLR) (CIK 0001124198) (FLR) — Mar 30, 2005
FLUOR CORP (FLR) (CIK 0001124198)
Date: March 30, 2005 · CIK: 0001124198 · Accession: 0000000000-05-015075
AI Filing Summary & Sentiment
Letter
March 29, 2005 Via U.S. Mail Alan L. Boeckmann Chief Executive Officer Fluor Corporation One Enterprise Drive Aliso Viejo, California 92656
RE: Fluor Corporation Form 10-K for the fiscal year ended December 31, 2004 File No. 1-16129
Dear Mr. Boeckmann:
We have limited our review of your Form 10-K to disclosures relating to your contacts with countries that have been identified as state sponsors of terrorism, and will make no further review of the Form 10-K. Our review with respect to this issue does not preclude further review by the Assistant Director group with respect to other issues. At this juncture, we are asking you to provide us with supplemental information, so that we may better understand your disclosure. Please be as detailed as necessary in your response. After reviewing this information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filings. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
General -
We note that in Exhibit 21 to its 10-K for the fiscal year ended December 31, 2004, the Company lists both tier II and tier III subsidiaries named Fluor Iran. In light of the fact that Iran has been identified by the U.S. State Department as a state sponsor of terrorism, and is subject to economic sanctions administered by the U.S. Treasury Department`s Office of Foreign Assets Control, please describe for us the extent of the Company`s operations in, or contacts with, Iran; the materiality to the Company of any such operations or contacts; and your view as to whether those operations or contacts constitute a material investment risk for your security holders. In preparing your response please consider that evaluations of materiality should not be based solely on quantitative factors, but should include consideration of all factors, including the potential impact of corporate activities upon a company`s reputation and share value, that a reasonable investor would deem important in making an investment decision.
On page 1 of its 10-K, the Company states that it is a "primary service provider to the United States federal government." On page 11 of its 10-K, the Company states that "[o]perating in the international marketplace exposes us to a number of risks" including "United States government policies", and "international hostilities". It also notes that it faces "significant risk due to civil strife, acts of war, terrorism and insurrection." Please also tell us whether the Company`s operations in, or contacts with, Iran, if any, could adversely affect its position as a service provider to the U.S. government, and discuss for us the nature and extent of any such potential adverse effect.
Closing
Please understand that we may have additional comments after we review your response to our comment. Please contact Jack Guggenheim at (202) 942-7896 if you have any questions about the comment or our review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
Show Raw Text
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<TEXT>
March 29, 2005
Via U.S. Mail
Alan L. Boeckmann
Chief Executive Officer
Fluor Corporation
One Enterprise Drive
Aliso Viejo, California 92656
RE: Fluor Corporation
Form 10-K for the fiscal year ended December 31, 2004
File No. 1-16129
Dear Mr. Boeckmann:
We have limited our review of your Form 10-K to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 10-K. Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues. At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure. Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects. We welcome
any questions you may have about our comments or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
General -
We note that in Exhibit 21 to its 10-K for the fiscal year ended
December 31, 2004, the Company lists both tier II and tier III
subsidiaries named Fluor Iran. In light of the fact that Iran has
been identified by the U.S. State Department as a state sponsor of
terrorism, and is subject to economic sanctions administered by
the
U.S. Treasury Department`s Office of Foreign Assets Control,
please
describe for us the extent of the Company`s operations in, or
contacts with, Iran; the materiality to the Company of any such
operations or contacts; and your view as to whether those
operations
or contacts constitute a material investment risk for your
security
holders. In preparing your response please consider that
evaluations
of materiality should not be based solely on quantitative factors,
but should include consideration of all factors, including the
potential impact of corporate activities upon a company`s
reputation
and share value, that a reasonable investor would deem important
in
making an investment decision.
On page 1 of its 10-K, the Company states that it is a "primary
service provider to the United States federal government." On
page
11 of its 10-K, the Company states that "[o]perating in the
international marketplace exposes us to a number of risks"
including
"United States government policies", and "international
hostilities".
It also notes that it faces "significant risk due to civil strife,
acts of war, terrorism and insurrection." Please also tell us
whether the Company`s operations in, or contacts with, Iran, if
any,
could adversely affect its position as a service provider to the
U.S.
government, and discuss for us the nature and extent of any such
potential adverse effect.
Closing
Please understand that we may have additional comments after
we
review your response to our comment. Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review. You may also contact me at (202) 942-7817.
Sincerely,
Cecilia D. Blye, Chief
Office of Global Security
Risk
cc: Pamela Long
Assistant Director
Division of Corporation Finance
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Alan L. Boeckmann
Fluor Corporation
March 29, 2005
Page 1
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0507
DIVISION OF
CORPORATION FINANCE
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