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SEC Comment Letter for Future FinTech Group Inc. (FTFT) (CIK 0001066923) (FTFT) — Aug 20, 2018

Future FinTech Group Inc. (FTFT) (CIK 0001066923)
Date: Aug. 20, 2018 · CIK: 0001066923 · Accession: 0000000000-18-025698

Digital Assets / Emerging Issues Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-224686

Date
August 17, 2018
Author
/s/ Loan Lauren P. Nguyen for
Form
UPLOAD
Company
Future FinTech Group Inc. (FTFT) (CIK 0001066923)

Letter

Mail Stop 4628 August 17, 2018 Yongke Xue Chief Executive Officer Future FinTech Group Inc. 23F, National Development Bank Tower No. 2 Gaoxin 1st Road, Xi’an, PRC 710075

Re: Future FinTech Group Inc. Registration Statement on Form S-3 Response dated August 6, 2018 File No. 333-224686

Dear Mr. Yongke Xue:

We have reviewed your response letter and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the requested information . If you do not believe our com ments apply to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to these comments, w e may have additional comments. Unless we note otherwise, our references to prior comments are to comments in our July 17, 2018 letter .

General

1. We note your response to comment 3 that the DCON platform is and the Shared Shopping Mall platform will be gl obally accessible, but that you will implement measures to ensure new tokens are not issued “in the U.S. or to U.S. citizens.” Please expand your disclosure to clarify whether the services and products provided on your digital platforms will be available to U.S. persons or if you intend to block U.S. persons from using your platforms. To the extent that certain products and services on your digital platforms will be available to U.S. persons, please describe the activities that may be available on such pl atforms.

Yongke Xue Future FinTech Group Inc. August 17, 2018 Page 2

Please contact Karina V. Dorin, Staff Attorney, at (202) 551 -3763 or Loan Lauren P. Nguyen, Legal Branch Chief, at (202) 551 -3642 w ith any questions.

Sincerely,
/s/ Loan Lauren P. Nguyen for

Show Raw Text
Mail Stop 4628
August 17, 2018

Yongke Xue
Chief Executive Officer
Future FinTech Group Inc.
23F, National Development Bank Tower
No. 2 Gaoxin 1st Road, Xi’an, PRC 710075

Re: Future FinTech Group Inc.
  Registration Statement on Form S-3
Response dated August 6, 2018
  File No.  333-224686

Dear Mr. Yongke Xue:

We have reviewed your response letter and have the following comments.  In  some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our com ments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, w e may have  additional comments.   Unless we note
otherwise, our references to prior comments are to comments in our July 17, 2018 letter .

General

1. We note your response to comment 3 that the DCON platform is and the Shared
Shopping Mall platform will be gl obally accessible, but that you will implement
measures to ensure new tokens are not issued “in the U.S. or to U.S. citizens.”   Please
expand your disclosure to clarify whether the services and products provided on your
digital platforms will be available to U.S. persons or if you intend to block U.S. persons
from using your platforms.   To the extent that certain products and services on your
digital platforms will be available to U.S. persons, please describe the activities that may
be available on such pl atforms.

Yongke Xue
Future FinTech Group Inc.
August 17, 2018
Page 2

 Please contact Karina V. Dorin, Staff Attorney, at (202) 551 -3763  or Loan Lauren P.
Nguyen, Legal Branch Chief, at (202) 551 -3642 w ith any questions.

Sincerely,

 /s/ Loan Lauren P. Nguyen  for

John Reynolds
Assistant Director
Office of Natural Resources