-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, Ds6X48LAGJCUcALkm1gRcFlYhMruhFDsdTDJCkkdeouQ1hvRjCA+dprJUtV66I38 PENVERJV55ljKOdfPMDheA== 0000000000-07-031610.txt : 20071012 0000000000-07-031610.hdr.sgml : 20071012 20070628105830 ACCESSION NUMBER: 0000000000-07-031610 CONFORMED SUBMISSION TYPE: UPLOAD PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20070628 FILED FOR: COMPANY DATA: COMPANY CONFORMED NAME: WILLIS GROUP HOLDINGS LTD CENTRAL INDEX KEY: 0001140536 STANDARD INDUSTRIAL CLASSIFICATION: INSURANCE AGENTS BROKERS & SERVICES [6411] IRS NUMBER: 000000000 STATE OF INCORPORATION: D0 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: UPLOAD BUSINESS ADDRESS: STREET 1: TEN TRINITY SQUARE CITY: LONDON ENGLAND STATE: X0 ZIP: 00000 BUSINESS PHONE: 0114402074 MAIL ADDRESS: STREET 1: TEN TRINITY SQUARE CITY: LONDON ENGLAND STATE: X0 ZIP: 00000 PUBLIC REFERENCE ACCESSION NUMBER: 0001047469-06-002748 LETTER 1 filename1.txt June 28, 2007 Via U.S. Mail and Facsimile (011-44-207-488-8034) Patrick Regan Group Chief Financial Officer Willis Group Holdings Limited c/o Willis Group Limited Ten Trinity Square, London EC3P 3AX, England Re: Willis Group Holdings Limited Form 10-K for the Fiscal Year Ended December 31, 2005 Filed March 2, 2006 Response Letters dated March 28, 2007 and May 30, 2007 File No. 1-16503 Dear Mr. Regan: We have reviewed your response letter dated May 30, 2007 and have the following comment. We welcome any questions you may have about our comment 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 1. You state in your response letter dated May 30, 2007 that your non-US subsidiaries have provided services to clients from countries including Syria with insurable interests in Iran or cargo being transported to Iran. Syria is identified by the U.S. as a state sponsor of terrorism and is subject to U.S. economic sanctions and export controls. Please provide us with the same type of information regarding your contacts with Syria as we requested in comments 1 and 2 of our letter dated February 21, 2007 regarding your contacts with Iran and Sudan. Include a description of the business(es) conducted by your client(s) in Syria and the services you provide to your clients in Syria. * * * * * Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please file your response letter on EDGAR. Please understand that we may have additional comments after we review your response to our comment. Please contact Pradip Bhaumik, Attorney-Advisor, at (202) 551-3333 if you have any questions about the comment or our review. You may also contact me at (202) 551- 3470. Sincerely, Cecilia D. Blye, Chief Office of Global Security Risk cc: Jeffrey Riedler Assistant Director Division of Corporation Finance Patrick Regan Willis Group Holdings Limited June 28, 2007 Page 1 -----END PRIVACY-ENHANCED MESSAGE-----