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
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