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  The Brink’s Company

1801 Bayberry Court

P.O. Box 18100

Richmond, VA 23226-8100 U.S.A.

Tel: (804) 289-9600

October 22, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, N.E.

Washington, D.C. 20549

Attn: Yong Kim and Karl Hiller

    Re:

    The Brink’s Company

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Filed February 29, 2024

    File No. 001-09148

Ladies and Gentlemen:

On behalf of The Brink’s
Company (the “Company” or “Brink’s”), set forth below is the response to the
comments received from the staff (the “Staff”) of the Securities and Exchange Commission’s (the “Commission”)
Division of Corporation Finance (the “Division”) by letter dated September 23, 2024, with respect to the
Annual Report on Form 10-K for the fiscal year ended December 31, 2023, filed with the Commission on February 29, 2024
(the “Form 10-K”), File No. 001-09148. The Company’s General Counsel's office
reached out to Yong Kim from the Staff on September 26, 2024. Pursuant to that conversation, the Staff granted an extension to respond
to the comment letter until October 23, 2024.

For your convenience, our
responses are prefaced by the exact text of the Staff’s comments in bold, italicized text.

Form 10-K for the Fiscal Year Ended December 31,
2023

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 2

Management’s Discussion and Analysis of Financial
Condition and Results of Operations

Results of Operations, page 24

1.            We
note that you identify three non-GAAP measures when describing the purpose of your non-GAAP information on page 24, as "to report
our operating profit, income from continuing operations and earnings per share without certain income and expense items that do not reflect
the regular earnings of our operations." You indicate that you do not consider the excluded items to be reflective of your core operating
performance. However, you refer to pages 35-37 for the reconciliations which appear to cover not only those measures but also eight
additional non-GAAP measures, and it appears that you have another four non-GAAP measures on page 40 and 42.

Please revise your description
of purpose as necessary to explain your rationale for each non-GAAP measure that you present to comply with Item 10(e)(1)(i)(C) of
Regulation S-K; it should be clear why you believe each measure provides useful information to investors regarding your financial condition
and results of operations. Given that you identify measures of revenue, capital expenditures and financing leases as both GAAP and non-GAAP
measures, also revise the labels as necessary to identify the measures as either GAAP or non-GAAP.  Your disclosures should
provide appropriate and clear differentiation between GAAP and non-GAAP measures.

Given that the excluded
items listed on page 28 include various recurring costs such as reorganization and restructuring, acquisitions and dispositions,
and the effects of inflation, please also expand your discussion and analysis of the non-GAAP measures on page 25 to clarify
the nature of the recurring costs that have been excluded from your non-GAAP measures and to explain why activity associated with the
costs is not relevant to understanding your core operating performance or regular earnings, in your view.

The Company acknowledges
the Staff’s comments and will revise the descriptions of non-GAAP measures in future filings to describe each non-GAAP measure
used in the filing and why the Company believes each measure provides useful information to investors regarding the Company’s financial
condition and results of operations. The Company will also revise labels of measures in future filings to clarify which measures are
GAAP and non-GAAP. Exhibit A attached hereto sets forth the relevant sections from the Form 10-K, revised to reflect this updated
disclosure. Exhibit A-1 provides a clean version of the proposed Management’s Discussion and Analysis language. Exhibit A-2
includes a version of such disclosure marked to show changes from the Form 10-K language. See page 15 of Exhibit A-1 for
example language of updated descriptions and rationale.

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 3

To provide more clarity in
future filings, where the GAAP and non-GAAP measures for the periods presented are the same (such as revenue, capital expenditures and
financing leases), references to “non-GAAP” with respect to those measures will be removed.

Future filings will also include
an expanded discussion of each non-GAAP adjustment describing the nature of the adjustment and why the Company believes it is not relevant
to core operating performance or regular earnings. Example expanded disclosure is included throughout Exhibit A-1 where each adjustment
is first described, including on pages 8-10 and 16. See also the response to comment 3 below for more background on the exclusion
of such items from the non-GAAP measures.

Income and Expense Not Allocated to Segments

Corporate Expenses, page 28

2.            We
note that the second table on page 28 is identified as “Other Items Not Allocated to Segments” although items within
the table are preceded by the label “Operating profit” and the sum of the items is labeled in an identical manner.
Please correct the labels utilized to characterize the amounts presented within the tabulation.

With regard to unallocated
costs, please disclose the criteria utilized to report such costs as either corporate expenses, which are in turn reflected in your non-GAAP
measures, or as other items which are excluded from your non-GAAP measures, and explain how that criteria serves to appropriately
differentiate between items that are representative of "core operating performance" or "regular earnings" and
items that are not, in your view.

The Company acknowledges the
Staff’s comments and will revise the “Other Items Not Allocated to Segments” table to provide clarifying labels and
descriptions. See page 7 of Exhibit A-1 for example language for such updated table.

The Company first considers
if items should be included or excluded from non-GAAP measures based on whether or not we consider them to be part of the Company’s
operations and revenue generating activities. Items that are included in non-GAAP measures are reported in either Corporate expenses or
in segment results. Items that are excluded from non-GAAP measures would otherwise have been in either Corporate or segment results and
are reported as Other Items not Allocated to Segments.

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 4

Corporate expenses include
costs to manage the global business and perform activities required by public companies, as well as other items that are considered part
of the Company’s operations and revenue generating activities, but are not considered when the chief operating decision maker ("CODM")
evaluates segment results. Examples include corporate staff compensation, corporate headquarters costs, regional management costs, share-based
compensation, and currency transaction gains and losses.

Other Items not Allocated
to Segments include income and expenses that are not necessary to operate the Company's business in the ordinary course and are not considered
when the CODM evaluates segment results. These include non-recurring, as well as certain recurring costs and gains. The Company believes
each of the items in the “Other Items Not Allocated to Segments” table is appropriately excluded from non-GAAP measures as
they are not considered to be part of the Company's operations and revenue generating activities. See pages 7-10 of Exhibit A-1
for additional disclosures to be provided in future filings regarding this criteria.

Non-GAAP Results Reconciled to GAAP, page 35

3.            Given
the emphasis you have placed on non-GAAP measures throughout MD&A, and considering language characterizing your non-GAAP measures
as more representative of core operating performance and regular earnings than the corresponding GAAP measures, it is unclear how you
have considered our Compliance and Disclosure Interpretations (C&DI's) on Non-GAAP measures in formulating your disclosures.

 · Provide us with an analysis of each adjustment showing how you considered the guidance
in Question 100.01 of our C&DI's, as to whether the excluded item represents a normal, recurring, cash operating expense necessary
to operate your business, and explaining how your exclusion of any amount designated as such would not cause the resulting measure to
be misleading in your view.

 · Please address the guidance in Question 102.10(c) of our C&DI's with respect to your presentation
of non-GAAP measures in each section of your discussion and analysis, and submit the revisions that you propose to restore balance to
the disclosures and to avoid giving undue prominence to your presentation of non-GAAP measures.

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 5

You may view the C&DI's on Non-GAAP
measure at the following address: https://www.sec.gov/corpfin/non-gaap-financial-measures.htm.

The Company acknowledges the
Staff’s comment and has considered the guidance set forth in Question 100.01 of the Staff’s C&DIs. When the Company adjusts
for costs and gains in determining non-GAAP measures, the Company evaluates the nature and effect of the excluded items and whether or
not these items impact the Company’s operations and revenue generating activities. Based on those evaluations, the Company considers
whether the exclusion of a cost or gain could be viewed as misleading. The Company believes the exclusions are not misleading because
each item is non-recurring and/or not representative of the ongoing operations of the Company’s business, as described below:

 · Reorganization and Restructuring

 ○ These net charges relate to the Company's previously announced 2022 Global Restructuring Plan and other
targeted restructuring actions, primarily severance charges and asset impairment losses. The 2022 Global Restructuring Plan was designed
to, among other things, establish a more efficient operating structure post-COVID-19 pandemic and anticipate potential macroeconomic challenges
in light of the COVID-19 pandemic. Other restructuring actions were primarily in response to the COVID-19 pandemic and
decision to exit a line of business in the Company's Canada operating unit.  Due to
the unusual nature of the underlying events that led to these actions, the charges are not considered part of the Company’s operations
and revenue generating activities. Management has excluded these amounts when evaluating internal performance.  As such, they have
not been allocated to segment or Corporate results and are excluded from non-GAAP results.

 · Acquisitions and dispositions

 ○ Certain acquisition and disposition items, such as amortization expense for acquisition-related intangible
assets, integration, transaction, restructuring and certain compensation costs, are not part of the Company’s operations and revenue
generating activities. Additionally, amortization expense is a non-cash expense. All of the items are significantly impacted by the timing
and nature of acquisitions and dispositions, and many are inconsistent in amount and frequency. Management has excluded these amounts
when evaluating internal performance.  Therefore, the Company has not allocated these amounts to segment or Corporate results and
has excluded these amounts from non-GAAP results.

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 6

 · Argentina highly inflationary impact

 ○ As a result of the Company designating Argentina's economy as highly inflationary in 2018, Argentine peso-denominated
monetary assets and liabilities are remeasured at each balance sheet date, with remeasurement gains and losses recognized in earnings.
In addition, nonmonetary assets retain a higher historical basis, resulting in higher incremental expense being recognized when the assets
are consumed.  These are non-cash charges, and not part of the Company’s operations and revenue generating activities. Management
has excluded these amounts when evaluating internal performance.  As such, they have not been allocated to segment or Corporate results
and are excluded from non-GAAP results.

 · Transformation initiatives

 ○ During 2023, the Company initiated a multi-year program intended to transform its business model and standardize
systems and processes to achieve accelerated growth and margin expansion. The transformation costs primarily include third-party professional
services and project management charges. As these costs relate to a discrete program and are not reflective of the Company's ongoing operating
cost structure, they are not indicative of the Company’s core operating expenses or normal activities. Additionally, management
has excluded these amounts when evaluating internal performance.  As such, they have not been allocated to segment or Corporate results
and are excluded from non-GAAP results.

 · Non-routine auto loss matter:

 ○ In 2023, the Company recognized a charge related to litigation around a motor vehicle accident that resulted
in the death of a third party. Due to the unusual nature of the matter, including the unique circumstances of the claim, potential magnitude
of remedy, and variation from the Company’s ordinary-course litigation strategy, the Company considers the litigation as separate
and distinct from routine legal matters. Management does not believe that similar litigation will likely recur within the next two years,
and there have been no similar matters within the prior two years. Management has excluded these amounts when evaluating internal performance.
Therefore, they have not been allocated to segment or Corporate results and are excluded from non-GAAP results.

  U.S. Securities and Exchange Commission

                         October 22, 2024

Page 7

 · Change in allowance estimate

 ○ The Company recorded a charge that resulted from revising its methodology in estimating its allowance
for doubtful accounts after experiencing significantly aged balances that arose primarily during the pandemic. The charge was not reflective
of the Company’s operations and revenue generating activities in the period the charge was recorded. Additionally, given the unusual
nature of the events that led to the charge (i.e., the COVID-19 pandemic), a similar charge is not reasonably likely to recur within two
years, nor were similar costs incurred within the prior two years. Management has excluded these amounts when evaluating internal
performance. Therefore, they have not been allocated to segment or Corporate results and are excluded from non-GAAP results.

 · Ship loss matter

 ○ In 2022, the Company recorded a charge for an estimated probable loss associated with a claim from a ship
owner. In 2015, the Company placed cargo containing customer valuables on a ship which suffered extensive damages and losses of cargo.
The Company’s cargo did not suffer any damage. However, the ship owner declared a "general average claim," an ancient
maritime law principle, to recover losses from customers with undamaged cargo based on the pro rata value of ship cargo. Due to the unusual
nature of the events that led to the charge, a similar charge is not reasonably likely to recur within two years, nor were similar costs
incurred within the prior two years. Management has excluded this amount when evaluating internal performance. Therefore, it has not been
allocated to segment or Corporate results and is excluded from non-GAAP results.

 · Chile antitrust matter

 ○ The Company has recorded charges for a contingent loss associated wi