An analytical model is developed to analyze the seismic response of gravity walls retaining and founded on dry sand, with special emphasis on tilting behavior. A well verified two-dimensional finite element code is used for this purpose. The analytical model is verified comparing predictions to results from three dynamic centrifuge tests, with satisfactory agreement. Moreover, sensitivity analyses are carried out for one of the centrifuge test conditions to understand how the results would change if the boundary conditions and rotational stiffness of the wall were changed