SecProbe.io

CORRESP
 1
 filename1.htm

 Okeanis Eco Tankers
Corp.

 c/o OET Chartering
Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece
Tel: +30 210 480 4200

 May 19, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Re: Okeanis Eco Tankers Corp.

 Registration Statement
on Form F-3 (File No. 333-287036)

 Ladies and Gentlemen:

 The
undersigned registrant hereby requests that the effectiveness of the above-captioned Registration Statement on Form F-3 that
was filed with the U.S. Securities and Exchange Commission on May 7, 2025 be accelerated so that it will be made effective
at 5:00 p.m. Eastern Time on May 21, 2025, or as soon thereafter as practicable, pursuant to Rule 461(a) of the Securities
Act of 1933, as amended (the " Act ").

 The
undersigned registrant is aware of its obligations under the Act.

 Should
you have any questions regarding this request, please do not hesitate to contact Steven J. Hollander, Esq. of Watson Farley &
Williams LLP, counsel to the undersigned registrant, at (212) 922-2252.

 Yours truly,

 Okeanis Eco Tankers Corp.

 By:
 /s/ Iraklis Sbarounis

 Name:
 Iraklis Sbarounis

 Title:
 Chief Financial Officer

CORRESP
 1
 filename1.htm

 Okeanis Eco Tankers
Corp.

 c/o OET Chartering
Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece
Tel: +30 210 480 4200

 May 19, 2025

 VIA EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, NE

 Washington, D.C. 20549

 Re: Okeanis Eco Tankers Corp.

 Registration Statement on Form F-3 (File
 No. 333-287032)

 Ladies and Gentlemen:

 The
undersigned registrant hereby requests that the effectiveness of the above-captioned Registration Statement on Form F-3 that
was filed with the U.S. Securities and Exchange Commission on May 7, 2025 be accelerated so that it will be made effective
at 5:00 p.m. Eastern Time on May 21, 2025, or as soon thereafter as practicable, pursuant to Rule 461(a) of the Securities
Act of 1933, as amended (the " Act ").

 The
undersigned registrant is aware of its obligations under the Act.

 Should
you have any questions regarding this request, please do not hesitate to contact Steven J. Hollander, Esq. of Watson Farley &
Williams LLP, counsel to the undersigned registrant, at (212) 922-2252.

 Yours truly,

 Okeanis Eco Tankers Corp.

 By:
 /s/ Iraklis Sbarounis

 Name:
 Iraklis Sbarounis

 Title:
 Chief Financial Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 14, 2025

Iraklis Sbarounis
Chief Financial Officer
Okeanis Eco Tankers Corp.
c/o OET Chartering Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece

 Re: Okeanis Eco Tankers Corp.
 Registration Statement on Form F-3
 Filed May 7, 2025
 File No. 333-287036
Dear Iraklis Sbarounis:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Claudia Rios at 202-551-8770 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Steven Hollander, Esq.
</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 14, 2025

Iraklis Sbarounis
Chief Financial Officer
Okeanis Eco Tankers Corp.
c/o OET Chartering Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece

 Re: Okeanis Eco Tankers Corp.
 Registration Statement on Form F-3
 Filed May 7, 2025
 File No. 333-287032
Dear Iraklis Sbarounis:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 Claudia Rios at 202-551-8770 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Steven Hollander, Esq.
</TEXT>
</DOCUMENT>

CORRESP
1
filename1.htm

December
4, 2023

VIA EDGAR

Securities and Exchange
Commission

Division of Corporation
Finance

100 F. Street, N.E.

Washington, D.C. 20549-3561

 Re: Okeanis Eco Tankers Corp.

Registration
Statement on Form 20-F (File No. 001-41858)

Ladies and Gentlemen:

The
undersigned registrant hereby requests that the effectiveness of the above captioned Registration Statement, filed with the Securities
and Exchange Commission (the “Commission”) on Form 20-F on November 22, 2023, be accelerated so that it will be effective
at 04:00 PM Eastern Standard Time on December 6, 2023, or as soon thereafter as practicable, pursuant
to Section 12(d) and Rule 12d1-2 of the Securities Exchange Act of 1934 (the “Exchange Act”).

The
Company requests accelerated effectiveness of the Registration Statement in connection with the registration of the Company’s common
shares, par value of $0.001 per share, under Section 12(b) of the Exchange Act, and the planned listing of the Company’s common
shares on the New York Stock Exchange, and the admission of the Company’s common shares to trading thereon.

If
you have any questions regarding this request, please contact Steven Hollander of Watson Farley & Williams LLP, counsel to the undersigned
registrant, at +1 212 922 2252.

    Sincerely,

    Okeanis
    Eco Tankers Corp.

    By:
    /s/ Iraklis Sbarounis

    Name:
    Iraklis Sbarounis

    Title:
    Chief Financial Officer

CORRESP
1
filename1.htm

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Energy & Transportation

    100 F Street, N.E.

    Washington, D.C. 20549

    Our Reference /33614.50007/US/80882299v1

November 22, 2023

Okeanis Eco Tankers Corp.

Registration Statement on Form 20-F

Filed November 2, 2023

CIK No. 0001964954

Ladies and Gentlemen:

Okeanis Eco Tankers Corp. (the “Company”)
is today filing with the U.S. Securities and Exchange Commission an amendment no. 1 to the registration statement on Form 20-F (the “Registration
Statement”). The Company previously filed its registration statement on Form 20-F on November 2, 2023 (the “Previous
Registration Statement”). After the filing of the Previous Registration Statement, the Company published on November 9, 2023,
through the Oslo Børs, financial information relating to the nine month period ending September 30, 2023. Item 8.A.5 of Form 20-F
provides that if “the company has published interim financial information that covers a more current period than those otherwise
required by this standard, the more current interim financial information must be included in the document.” The Registration Statement
is therefore being filed to include the more current financial information that it published through the Oslo Børs, and a related
updated capitalization table. The Registration Statement also includes additional updates relating to the passage of time.

If you have any questions
or comments concerning this letter, please feel free to contact Steven Hollander at the undersigned at 212-922-2252.

Yours sincerely,

Watson Farley & Williams
LLP

/s/ Watson Farley &
Williams LLP

United States securities and exchange commission logo
October 5, 2023
Aristidis Alafouzos
Chief Executive Officer
Okeanis Eco Tankers Corp.
c/o OET Chartering Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece
Re:Okeanis Eco Tankers Corp.
Amendment No. 1 to Draft Registration Statement on Form 20-F
Submitted September 20, 2023
CIK No. 0001964954
Dear Aristidis Alafouzos:
            We have reviewed your amended draft registration statement and have the following
comment.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Our references to prior comments refer to comments in our August 23, 2023 letter.
Amendment No. 1 to Draft Registration Statement on Form 20-F submitted September 20, 2023
Notes to the Consolidated Financial Statements
Note 24. Revenue, page F-40
1.Please further expand the disclosure added in response to prior comment 15 to provide the
identity of the segment or segments reporting the revenues, as required by paragraph 34 of
IFRS 8.

 FirstName LastNameAristidis Alafouzos
 Comapany NameOkeanis Eco Tankers Corp.
 October 5, 2023 Page 2
 FirstName LastName
Aristidis Alafouzos
Okeanis Eco Tankers Corp.
October 5, 2023
Page 2
            Please contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or Kimberly Calder,
Assistant Chief Accountant, at 202-551-3701 if you have questions regarding comments on the
financial statements and related matters.  Please contact Claudia Rios, Staff Attorney, at 202-
551-8770 or Irene Barberena-Meissner, Staff Attorney, at 202-551-6548 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Steven Hollander, Esq.

United States securities and exchange commission logo
August 23, 2023
Aristidis Alafouzos
Chief Executive Officer
Okeanis Eco Tankers Corp.
c/o OET Chartering Inc.
Ethnarchou Makariou Ave., & 2 D. Falireos St.
185 47 N. Faliro, Greece
Re:Okeanis Eco Tankers Corp.
Draft Registration Statement on Form 20-F
Submitted July 26, 2023
CIK No. 0001964954
Dear Aristidis Alafouzos:
            We have reviewed your draft registration statement and have the following 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form 20-F submitted July 26, 2023
Market and Industry Data, page iv
1.We note your disclosure that information contained in your registration statement
concerning your industry and the markets in which you operate, including your general
expectations and market position, market opportunity and market size, is based on
industry publications and other published industry sources prepared by third parties,
including the International Energy Agency (“IEA”), Braemar Shipbroking Limited
(“Braemar”), and Bloomberg, as well as publicly available information.  Please revise to
include the names and dates of these reports.

 FirstName LastNameAristidis Alafouzos
 Comapany NameOkeanis Eco Tankers Corp.
 August 23, 2023 Page 2
 FirstName LastNameAristidis Alafouzos
Okeanis Eco Tankers Corp.
August 23, 2023
Page 2
Key Information
Risk Factors
Volatility of SOFR and potential changes of the use of SOFR as a benchmark ..., page 8
2.We note the statement that “All of our loan agreements no longer utilize LIBOR.”
 However, we note disclosure on page F-34 that you are required to make interest
payments based on LIBOR.  Please revise your disclosures as necessary to clarify this
discrepancy.
We conduct a substantial amount of business in China, whose legal system has inherent
uncertainties, page 24
3.We note your disclosure here that you conduct a substantial amount of business in China,
many of your vessels call to ports in China, and you have entered into and may further
enter in the future into sale and leaseback transactions with Chinese financial
institutions.  Please tell us whether the majority of your operations are in China.
We are a holding company, and we will depend on the ability of our subsidiaries to distribute
funds to us ..., page 40
4.We note your status as a holding company and dependence on your subsidiaries for cash
to make dividend payments.  Please explain to us your consideration of Rules 4-08(e), 5-
04(c) Schedule I and 12-04 of Regulation S-X.
Information on the Company
Business Overview
Our Business Strategies, page 47
5.We note your disclosure on page 48 that as of December 31, 2022, your leverage ratio was
approximately 61%.  Please include disclosure to clarify how this ratio was calculated.  If
any components of the ratio are non-GAAP, please provide disclosures required by Item
10(e) of Regulation S-K.
Operating and Financial Review and Prospects
Results of Operations
Recent Developments, page 92
6.We note the tables included on pages 93 through 95 are referred to as “unaudited selected
financial results for the three months ended March 31, 2023 and 2022.”  However, it
appears from their level of detail that these tables are a more comprehensive set of interim
financial statements.  Please tell us why you have provided this information in Item 5 as
opposed to Item 8.  See Form 20-F, Instruction 3 to Item 8.A.5.

 FirstName LastNameAristidis Alafouzos
 Comapany NameOkeanis Eco Tankers Corp.
 August 23, 2023 Page 3
 FirstName LastNameAristidis Alafouzos
Okeanis Eco Tankers Corp.
August 23, 2023
Page 3
Comparison on Previous Years
Year ended December 31, 2022 compared with the year ended December 31, 2021
Voyage expenses, page 96
7.We note that the increase in voyage expenses is attributed to two factors, higher
employment of vessels in the spot market and higher bunker fuel costs. Please revise to
quantify each factor cited so that investors may understand the magnitude and relative
impact of each factor. Furthermore, please review your discussion regarding comparison
of previous years for areas where further quantification of causal factors can be provided.
Credit Facilities and Financing Obligations
$125.7 Million Secured Term Loan Facility, page 103
8.We note your disclosure on page 46 that in May 2022, you signed your first sustainability
linked loan (“SLL”) that includes customary environmental clauses which are linked to
pricing, and gross proceeds from the transaction were $125.7 million which was used
towards the refinancing of debt outstanding under VLCC vessel Nissos
Kythnos and Nissos Donoussa, and for general corporate purposes.  Please disclose these
environmental clauses, including how they are linked to pricing.  Please also
disclose whether you or a third-party will assess your compliance with such clauses and
whether any such assessment will be made publicly available.
Directors, Senior Management and Employees
Compensation, page 112
9.We note the disclosure that each of your executive officers has an employment agreement
with you.  Please revise to describe the material terms of the respective agreements and
file such agreements as exhibits to your registration statement or provide an analysis
explaining why this is not necessary.  For guidance, refer to Instructions As To Exhibits to
Form 20-F.
Financial Information
Dividend Policy, page 118
10.You disclose that subject to certain limitations, you seek to offer your shareholders with a
competitive yield which is reflective of the cash flows generated by you and intend to pay
dividends in an amount that is close to your net profits, after adjusting for non-recurring
items, working capital needs, your capital structure and other discretionary items as your
board of directors decides, from time to time.  Please revise to explain how you define
"net profits" and "close to net profits."

 FirstName LastNameAristidis Alafouzos
 Comapany NameOkeanis Eco Tankers Corp.
 August 23, 2023 Page 4
 FirstName LastNameAristidis Alafouzos
Okeanis Eco Tankers Corp.
August 23, 2023
Page 4
11.We note your disclosure on page 39 that you can provide no assurance that dividends will
be paid in the future and there may be a high degree of variability from period to period in
the amount of cash, if any, that is available for the payment of dividends.  Please also
include this disclosure here and provide a cross-reference to the risk factor addressing
these risks.
12.Please disclose whether your dividend policy is reflected in any written policies of the
company.
13.We note your disclosure that your financing arrangements impose certain limitations on
your ability to pay dividends and your subsidiaries’ ability to make distributions to you.
Please revise your disclosure to describe the limitations on your ability to pay dividends
under your existing financing arrangements.
Note 4. Summary of Significant Accounting Policies
Vessel revenue recognition, page F-10
14.We note disclosure on page F-11 indicating that your voyage charter agreements contain a
“demurrage” or “despatch” clause.  If this represents variable consideration, please revise
your disclosure to address the disclosure requirements in IFRS 15 as it relates to variable
consideration or tell us why such disclosure is not required.
Segment Information, page F-14
15.We note disclosure on page 49 of individual customers accounting for more than 10% of
your revenues during the years ended December 31, 2022, 2021, and 2020.  Please expand
your footnote to provide the information about major customers as required by paragraph
34 of IFRS 8 or tell us why such disclosure is not required.
Note 24. Revenue, page F-40
16.Please tell us how you have complied with paragraph 113 of IFRS 15, which requires
disclosure of revenue recognized from contracts with customers separately from other
sources of revenue.  In this regard, we note the Time Charter revenue reflected in the table
on page F-40 includes the lease component recognized in accordance with IFRS 16.
17.The Time Charter revenue for 2020 of $96,186,965 does not agree to the total revenue
detailed in Note 21 on page F-37 of $100,623,909.  Please revise your disclosures as
necessary to clarify this discrepancy.

 FirstName LastNameAristidis Alafouzos
 Comapany NameOkeanis Eco Tankers Corp.
 August 23, 2023 Page 5
 FirstName LastName
Aristidis Alafouzos
Okeanis Eco Tankers Corp.
August 23, 2023
Page 5
            You may contact Jennifer O'Brien, Staff Accountant, at (202) 551-3721 or Kimberly
Calder, Assistant Chief Accountant, at (202) 551-3701 if you have questions regarding
comments on the financial statements and related matters.  Please contact Claudia Rios, Staff
Attorney, at (202) 551-8770 or Irene Barberena-Meissner, Staff Attorney, at (202) 551-6548
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       Steven Hollander, Esq.