SEC Comment Letter for CMB.TECH NV (CMBT) (CIK 0001604481) (CMBT) — Dec 21, 2017
CMB.TECH NV (CMBT) (CIK 0001604481)
Date: Dec. 21, 2017 · CIK: 0001604481 · Accession: 0000000000-17-044767
AI Filing Summary & Sentiment
Reasoning
Letter
December 21 , 2017 Via E -mail Patrick Rodgers Chief Executive Officer Euronav NV De Gerlachekaai 20, 2000 Antwerpen Belgium
Re: Euronav NV Form 20 -F for the Fiscal Year Ended December 31, 2016 Filed April 14 , 2017 File No. 1-36810
Dear Mr. Rodgers :
We have limited our review of your filing to your contacts with countries that have been identified as state sponsor s 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. At this juncture, we are asking you to provide 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 fact s and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comment s, we may have additional comments.
If our vessels call on ports located in countries that are subject to sanctions and em bargos imposed by the U.S. or other governments that could adversely affect our reputation and the market for our ordinary shares , page 14.
1. You indicate that from time to time, on charterers’ instructions, your vessels may call on ports in Sudan and Syri a, countries that are designated as state sponsors of terrorism by the U.S. Department of State and are subject to U.S. economic sanctions and /or export controls. You do not include disclosure about contacts with Sudan or Syria. Please describe to us the nature and extent of any past, current and anticipated contacts with Sudan and Syria, whether throug h subsidiaries, joint ventures, charterers, pool managers or other direct or indirect arrangements . You should descri be any goods, services or fees you have provided into Sudan and Syria, directly or indirectly, and any agreements, arrangements or other contacts you have had with the governments of Sudan and Syria or entities they control.
Patrick Rodgers Euronav NV December 21 , 2017 Page 2
2. Please tell us the approximate dollar amounts of any revenues, as sets and liabilities associated with Sudan and Syria for the last three fiscal years and the subsequent interim period.
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 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
Show Raw Text
December 21 , 2017
Via E -mail
Patrick Rodgers
Chief Executive Officer
Euronav NV
De Gerlachekaai 20, 2000 Antwerpen
Belgium
Re: Euronav NV
Form 20 -F for the Fiscal Year Ended December 31, 2016
Filed April 14 , 2017
File No. 1-36810
Dear Mr. Rodgers :
We have limited our review of your filing to your contacts with countries that have been
identified as state sponsor s 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. At this juncture, we are asking you to provide 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 fact s and circumstances, please tell us why in your response.
After reviewing the information you provide in response to these comment s, we may
have additional comments.
If our vessels call on ports located in countries that are subject to sanctions and em bargos
imposed by the U.S. or other governments that could adversely affect our reputation and the
market for our ordinary shares , page 14.
1. You indicate that from time to time, on charterers’ instructions, your vessels may call on
ports in Sudan and Syri a, countries that are designated as state sponsors of terrorism by
the U.S. Department of State and are subject to U.S. economic sanctions and /or export
controls. You do not include disclosure about contacts with Sudan or Syria. Please
describe to us the nature and extent of any past, current and anticipated contacts with
Sudan and Syria, whether throug h subsidiaries, joint ventures, charterers, pool managers
or other direct or indirect arrangements . You should descri be any goods, services or fees
you have provided into Sudan and Syria, directly or indirectly, and any agreements,
arrangements or other contacts you have had with the governments of Sudan and Syria or
entities they control.
Patrick Rodgers
Euronav NV
December 21 , 2017
Page 2
2. Please tell us the approximate dollar amounts of any revenues, as sets and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.
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 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: Anne Nguyen Parker
Assistant Director
Division of Corporation Finance