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 March 11, 2025

Aksel C. Olesen
Chief Financial Officer
SFL Corp Ltd.
14 Par-la-Ville Road
Hamilton HM08 Bermuda

 Re: SFL Corp Ltd.
 Form 20-F for the Fiscal Year ended December 31, 2023
 Filed March 14, 2024
 File No. 001-32199
Dear Aksel C. Olesen:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>

CORRESP
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filename1.htm

            Seward & Kissel llp

            ONE BATTERY PARK PLAZA

            NEW YORK, NEW YORK  10004

            TELEPHONE:  (212)  574-1200

            FACSIMILE:  (212) 480-8421

            WWW.SEWKIS.COM

            901 K STREET, N.W.

            WASHINGTON, D.C. 20001

            TELEPHONE:  (202) 737-8833

            FACSIMILE:  (202) 737-5184

  February 19, 2025

  Lily Dang & John Cannerella

  Office of Energy & Transportation

    Division of Corporation Finance

    Securities and Exchange Commission

    Washington D.C. 20549

          Re:

          SFL Corporation Ltd.

          Form 20-F for the Year Ended December 31, 2023

          Filed March 14, 2024

          File No. 001-32199

  Dear Ms. Dang and Mr. Cannerella:

  On behalf of SFL Corporation Ltd. (the “Company” or “SFL”), we are writing to respond to the comment set forth in the letter dated December 27, 2024, which was received by the Company on January 24, 2025, in which the staff (the “Staff”) of the U.S. Securities and Exchange Commission commented on the Company’s annual report on Form 20-F for the fiscal year ended December 31, 2023 (“2023 Form 20-F”). The Staff’s comment and the Company’s response are set forth below.

  We have reproduced below in bold italics the Staff’s comment and have provided the Company’s response
    immediately below the comment.

  The vast majority of the Company’s response reflects considerations made contemporaneously in the preparation of the 2023 Form 20-F.

  SEC Staff Comment

  We note your disclosure indicating you operate within a single reportable segment, although it is
    unclear how this reconciles with other disclosures in your earnings releases and investor presentations on your website, which identify and focus on five market categories, including container, car carrier, tanker, dry bulk, and energy.

  For example, within the investor presentations you report for each of these categories,
      the number and type of vessels, average contract duration, charter types, operating days, utilization, revenues, and operating expenses; and during some earnings calls you have referred to margins for particular vessels. We see that you discuss
      various risks that appear to be specific to the energy market category on page 15, and that drilling contract revenues for 2023 reflect a substantial increase, which was not characteristic of changes reported
      for the other revenue categories.

  Given the foregoing, please clarify how assessing performance and allocating resources would not be
    oriented towards, and informed by financial metrics associated with the five market categories that you have identified, if this is your view. Please explain to us how you considered and applied the guidance in FASB ASC 280-10-50-1, 10, 11 and 12,
    including the guidance specific to aggregation in 10-55-7A, B, and C, if applicable, in formulting your position regarding segment disclosures.

  As part of your response, please describe the information that is provided to your chief operating
    decision maker and the manner by which assessments of performance are conducted and decisions regarding resource allocations are made, with respect to the various market categories referenced above.

  However, if additional reportable segments are identified, please submit the revisions that you propose
    to address the requirements in FASB ASC 280. Please also revise your disclosures as necessary to clarify how the activity that is associated with each of the market categories correlates with your financial presentation. For example, if revenues of
    your energy market category are synonymous with your drilling contract revenues, this should be apparent from your disclosures.

  Response:

  The Staff has correctly noted the discussion in the Company’s earnings releases and investor presentations that discusses five market
    categories. However, that discussion is focused on revenue (and revenue-related comparisons) in each of those market categories. The Company’s earnings releases do not provide operating expenses or operating income by market category. Only one slide in
    its investor presentations touches on operating expenses by category and this is without any further discussion. Additionally, the Company does not present any measure of operating income (that is, revenues minus
      operating expenses) by market category.

  While each of these market categories is an important component of its business, they are not operating segments in accordance with ASC 280.
    Rather, they represent different market focuses or vessel types which are managed under the same strategy.

  The minimal emphasis on operating expenses by category in the Company’s investor presentations, and the complete omission of such information
    in its earnings releases, reflects the lack of attention paid to such information by the Company’s Chief Operating Decision Maker (“CODM”) in assessing performance and making decisions about how to allocate resources to components of the Company.

  Below is the Company’s consideration of the identification of operating segments as it pertains to the preparation of 2023 Form 20-F. The
    Company believes this summary is responsive to the points raised in the comment letter.

  Identification of the Chief Operating Decision Maker

  As discussed in ASC 280-10-50-5, the CODM is a function (not necessarily an individual) that allocates the resources of the reporting entity
    and assesses the performance of its segments. Decisions about the entity’s resource allocation and assessment of the entity’s businesses are made by the Company’s Board of Directors (the “Board”).

    The Board of SFL also includes the Chief Executive Officer (“CEO”), who is involved in strategic decisions. The Board approves all major capital expenditures, vessel acquisitions, disposals,
    long-term charter agreements, and financing transactions amongst other key decisions and does not have a fixed chairman.

  In 2023, the employees who reported directly to the CEO are the Chief Operating Officer (“COO”),

    Chief Financial Officer (“CFO”) and Senior Vice President – Business Development. Since January 2024, the Senior Vice President – Energy also began reporting directly to the CEO. These
    individuals are considered members of the senior management team of SFL. Due to the high number of major capital expenditures, vessel acquisitions, disposals, long-term charter agreements, financing transactions amongst other potential opportunities,
    which are screened by the Company, it is necessary that the senior management, together with the CEO, makes an initial decision about which proposals should be presented to the Board for consideration. However, the final decision is made by the Board
    as a whole.

  Based on the Company’s structure, it concluded that the Board constitutes the CODM. As a collective, the Board reviews the Company’s
    performance and makes decisions regarding the allocation of resources including capital investment in asset acquisitions and disposals, financing, long term charter agreements, key management hiring and other significant business decisions.

  Strategy of the Company

  The Company’s strategy as stated in Item 4.A of the 2023 20-F is “to generate stable and increasing cash flows by chartering our assets
    primarily under medium to long-term bareboat or time charters.”

  The CODM’s allocation of resources is not based on asset class, rather it is asset class neutral and instead pursues opportunities in line with
    the Company’s strategy.

  The Company would not plan to purchase a vessel or rig where it has not secured a medium or long term charter. In the last five years to
    December 31, 2023, the Company has acquired 28 vessels, all of which were secured on medium or long term charters at the time of the acquisition.

  The Company’s disclosures in Item 4.A of its Form 20-F for the years ended December 31, 2021, 2022 and 2023 shown below further demonstrate its
    strategy.

  “Acquisitions

  Year ended December 31, 2021:

        •

          In April 2021, we entered into an agreement with the Volkswagen Group to build and charter out two newbuild dual-fuel 7,000 CEU car carriers designed to use liquefied natural
            gas (“LNG”). The charter period is 10 years from delivery in 2023, and until the new vessels are delivered, the Volkswagen Group has chartered the two existing car carriers SFL Composer and SFL Conductor.

        •

          In August 2021, we acquired and took delivery of the 2013-built SFL Maui and the 2014-built SFL
              Hawaii, both with approximately 6,800 TEU carrying capacity. Upon delivery, the vessels each immediately commenced a six year time charter to Maersk.

        •

          Also in August 2021, we entered into an agreement with Kawasaki Kisen Kaisha Ltd. (“K Line”) to build and charter out two additional newbuild dual-fuel 7,000 CEU car carriers
            designed to use LNG. The charter period is 10 years from delivery of the vessels in 2024.

        •

          In September 2021, we acquired and took delivery of the 2020-built Maersk Zambezi which has a 5,300 TEU carrying capacity. Upon
            delivery, the vessel was chartered to Maersk on a time charter basis for approximately seven years.

        •

          In September 2021, we also acquired and took delivery of another two container vessels with 14,000 TEU carrying capacity, the 2013-built, Thalassa

              Patris and the 2014-built, Thalassa Elpida. Both vessels were on time charter to Evergreen Marine Corporation (Taiwan) Ltd (“Evergreen”) and we agreed
            to continue the obligations on these existing charterers. The two vessels are sister vessels to the four existing vessels we already had on charter to Evergreen.

        •

          In December 2021, we acquired and took delivery of the 2019-built Suezmax tanker Marlin Santorini. Upon delivery, the vessel commenced
            a five year time charter to Trafigura Maritime Logistics Pte. Ltd (“Trafigura”).

        •

          In December 2021, we acquired and took delivery of two 2015-built LR2 product tankers Front Puma and Front

              Tiger. Upon delivery, the vessels each commenced a five year time charter to Trafigura.”

  Year ended December 31, 2022:

        •

          In January 2022, we acquired and took delivery of two LR2 product tankers SFL Lion and SFL Panther,
            built in 2014 and 2015 respectively. Upon delivery, the vessels commenced five-year charters to Trafigura Maritime Logistics Pte Ltd (“Trafigura”).

        •

          In January 2022 and February 2022, we acquired and took delivery of two 2019-built Suezmax tankers, Marlin Sicily and Marlin Shikoku, respectively. Upon delivery, the vessels commenced five-year charters to Trafigura.

        •

          In August 2022, we agreed to acquire four 2015 and 2020 built modern eco-design Suezmax tankers, in combination with six-year charters to a subsidiary of Koch Industries. The
            vessels were delivered to us between September 2022 and November 2022.

        •

          In September 2022, we agreed to acquire two newbuild eco-design feeder container vessels, Maersk Phuket and Maersk Pelepas. The two vessels were delivered to us in September and November 2022, respectively, and immediately commenced seven-year charters to Maersk.

        •

          In November 2022, we took delivery of a 4,900 CEU car carrier, Arabian Sea, in combination with a six-year charter to Eukor.

  Year ended December 31, 2023:

        •

          During the year ended December 31, 2023, we had paid total installments and related costs of $158.4 million in relation to two dual-fuel 7,000 CEU newbuilding car carriers
            designed to use LNG under construction. The first of the vessels, Emden was delivered in September 2023, while the second vessel, Wolfsburg, was delivered in November 2023. On delivery, the vessels performed a voyage charter for an Asia based
            operator from Asia to Europe, and thereafter, the vessels started a 10-year time charter to Volkswagen Group.

        •

          Also, during the year ended December 31, 2023, we had paid total installments and related costs of $83.9 million in relation to another two dual-fuel 7,000 CEU newbuilding car
            carriers under construction. One of these vessels, Odin Highway, was delivered from the shipyard in January 2024 and immediately commenced a 10-year time charter to K Line. The second vessel, Thor Highway, is also expected to be delivered
            during the first half of 2024 and will immediately commence a 10-year time charter to K Line.”

  The Company is focused on maritime infrastructure investment, rather than operating as a traditional shipping company. This approach aims to
    avoid the volatility typically associated with market cycles and emphasizes the pursuit of stable and predictable revenue streams, regardless of asset type or market category. The CODM is solely responsible for this strategic direction and would
    determine if any changes are to be made in the future.

  Identification of Operating Segments

  The Company considered several sources of information when identifying its operating segments, including its organizational structure,
    information regularly reviewed by the CODM, Resource Allocation Decisions, the level at which budgets are reviewed and approved by the CODM, and an understanding of Senior Management’s Performance Assessment. As per ASC 280-10-50-1, an operating
    segment is a component of a public entity that has all of the following characteristics:

        a.

          It engages in business activities from which it may recognize revenues and incur expenses (including revenues and expenses relating to transactions with other components of the
            same public entity).

        b.

          Its operating results are regularly reviewed by the public entity’s chief operating decision maker to make decisions about resources to be allocated to the segment and assess
            its performance.

        c.

          Its discrete financial information is available.

  In consideration of ASC 280-10-50-1(a), the Company generates its revenues from the charter hire of its vessels and offshore related assets,
    and freight billings. Revenues are generated from time charter hire, bareboat charter hire, direct financing lease interest income, sales-type lease interest income, leaseback assets interest income, direct financing lease service revenues, profit
    sharing arrangements, drilling contract revenue, voyage charters and other freight billings. Similarly, the Company incurs costs in order to fulfil each of the various contract types in addition to general administrative and financing costs. Based on
    this information, the Company earns revenue and incurs expenses for each individual vessel or rig, and each of these components meets the criteria for “engaging in business activities for which it may earn revenues and incur expenses.”

  Information regularly reviewed by the CODM

  In accordance with ASC 280-10-50-1(b), one of the requirements to be an operating segment is that operating results for the component must be
    regularly reviewed by the CODM to allocate resources and assess performance.

  Although a Management Report (“MR”) is prepared by the accounting team and sent to senior management each quarter, the financial information presented and reviewed by the Board as CODM in the “Board Pack”, only includes an executive summary, the income statement, balance sheet, cashflow
    statement and a schedule showing Adjusted Earnings Before Interest, Tax, Depreciation and Amortisation (“EBITDA”)1.

  The Executive Summary includes consolidated financial informa

CORRESP
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filename1.htm

            Seward & Kissel llp

            ONE BATTERY PARK PLAZA

            NEW YORK, NEW YORK  10004

            TELEPHONE:  (212)  574-1200

            FACSIMILE:  (212) 480-8421

            WWW.SEWKIS.COM

            901 K Street, NW

            WASHINGTON, D.C. 20001

            TELEPHONE:  (202) 737-8833

            FACSIMILE:  (202) 737-5184

    February 10, 2025

    Via EDGAR

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Energy & Transportation

    100 F Street, N.E.

    Washington, DC 20549

            Re:

            SFL Corporation Ltd.

              Form 20-F for the fiscal year ended December 31, 2023

              Filed March 14, 2024

              File No. 001-32199

    Ladies and Gentlemen:

    On behalf of SFL Corporation Ltd. (the “Company”), we are writing in response to the letter of the staff (the “Staff”) of the U.S. Securities and Exchange
        Commission (the “SEC”) dated December 27, 2024 (the “Staff
        Letter”), which was received by the Company on January 24, 2025.  The Staff Letter relates to the above-referenced Form 20-F for the fiscal year ended December 31, 2023, which was filed on March 14, 2024.  As
        orally discussed with the Staff, the Company will respond to the Staff Letter by February 21, 2025.

    Thank you for your kind consideration. If you have any questions or require additional information, please do not hesitate to contact Keith J.
      Billotti of Seward & Kissel LLP,
      external legal counsel to the Company, at (212) 574-1274.

            Sincerely,

            By: /s/ Keith J. Billotti______

            Name: Keith J. Billotti

    cc: Aksel Olesen

December 27, 2024
Aksel C. Olesen
Chief Financial Officer
SFL Corp Ltd.
14 Par-la-Ville Road
Hamilton HM08 Bermuda
Re:SFL Corp Ltd.
Form 20-F for the Fiscal Year ended December 31, 2023
Filed March 14, 2024
File No. 001-32199
Dear Aksel C. Olesen:
            We have reviewed your filing and have the following comment.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Fiscal Year ended December 31, 2023
Financial Segments
Note 4. Segment Information, page F-20
We note your disclosure indicating you operate within a single reportable segment,
although it is unclear how this reconciles with other disclosures in your earnings
releases and investor presentations on your website, which identify and focus on five
market categories, including container, car carrier, tanker, dry bulk, and energy.

For example, within the investor presentations you report for each of these categories,
the number and type of vessels, average contract duration, charter types, operating
days, utilization, revenues, and operating expenses; and during some earnings calls
you have referred to margins for particular vessels.  We see that you discuss various
risks that appear to be specific to the energy market category on page 15, and
that drilling contract revenues for 2023 reflect a substantial increase, which was
not characteristic of changes reported for the other revenue categories.

 1.

December 27, 2024
Page 2
Given the foregoing, please clarify how assessing performance and allocating
resources would not be oriented towards, and informed by financial metrics associated
with the five market categories that you have identified, if this is your view. Please
explain to us how you considered and applied the guidance in FASB ASC 280-10-50-
1, 10, 11 and 12, including the guidance specific to aggregation in 10-55-7A, B, and
C, if applicable, in formulting your position regarding segment disclosures.

As part of your response, please describe the information that is provided to your
chief operating decision maker and the manner by which assessments of performance
are conducted and decisions regarding resource allocations are made, with respect to
the various market categories referenced above.

However, if additional reportable segments are identified, please submit the revisions
that you propose to address the requirements in FASB ASC 280.  Please also revise
your disclosures as necessary to clarify how the activity that is associated with each of
the market categories correlates with your financial presentation.  For example, if
revenues of your energy market category are synonymous with your drilling contract
revenues, this should be apparent from your disclosures.

            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 Lily Dang at 202-551-3867 or John Cannarella at 202-551-3337 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation