SecProbe.io

June 26 , 2018

Via E -mail
Edward Coll
Chairman of the Board and
Chief Executive Officer
Pangaea Logistics Solutions, Ltd .
c/o Phoenix Bulk Carriers (US) LLC
109 Long Wharf, Newport, RI 02840

 Re: Pangaea Logistics Solutions, Ltd .
  Form 10 -K for the Fiscal Year Ended December 31, 2017
  Filed March 21 , 2018
  File No. 1-36798

Dear Mr. Coll :

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 comment.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to oth er 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 prov ide the requested response.  If you do not
believe our comment applies to your facts and circumstances, please tell us why in your
response.

After reviewing the information you provide in response to this comment, we may have
additional comments.

Our v essels may 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 t he market for our
common shares, page 25.

1. You state that, on charterers’ instruction s, your vessels may call on ports or operate in
countries identified by the U.S. government as state sponsors of terrorism.  North Korea,
Sudan and Syria are among the countries that are designated as state sp onsors of
terrorism by the State Department and are subject to U.S. economic sanctions and /or
export controls.   You do not include disclosure about contacts with North Korea, Sudan
or Syria.  Please describe to us the nature and extent of any past, current and anticipated
contacts with North Korea, Sudan and Syria, including contacts with their governments,

Edward Coll
Pangaea Logistics Solutions , Ltd.
June 26 , 2018
Page 2

 whether throug h subsidiaries, joint ventures, charterers or other direct or indirect
arrangements .

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 comment 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