SecProbe.io

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 April 23, 2025

Matias Goldenh rn
Chief Executive Officer and Director
Athena Bitcoin Global
1 SE 3rd Avenue Suite 2740
Miami, Florida 33131

 Re: Athena Bitcoin Global
 Amendment No. 7 to Registration Statement on Form S-1
 Filed April 10, 2025
 File No. 333-262629
Dear Matias Goldenh rn:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our March 10,
2025 letter.

Amendment No. 7 to Registration Statement on Form S-1
Risk Factors
The theft, loss, or destruction of private keys required to access any Bitcoin
may be
irreversible..., page 28

1. We note your disclosure that "BitGo s custodial accounts are
segregated and secure,
 and BitGo carries insurance policies that may cover certain losses
(providing an
 additional layer of protection to the Company)." Please revise to
disclose the amount
 of coverage provided by BitGo's insurance policy and any coverage
limitations.
 April 23, 2025
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
White-label Service, page 61

2. We note your added disclosure on page 62 that "[i]f the user chooses to
receive the
 Bitcoin in a Chivo wallet, then the Government of El Salvador (through
the Chivo
 wallet system) retains custody of the private keys associated with that
wallet" and that
 "the end user does not have direct access to the private keys." Please
add a separately
 captioned risk factor addressing any risks attendant to the fact that
the Government of
 El Salvador (or its designated Chivo wallet operator) retains custody of
the private
 keys associated with the Chivo wallet system, as you state on page 62,
including
 any risk of loss or compromise of such private keys.
The Business
Athena Plus, page 94

3. We note your response to prior comment 8. We also note your disclosures
throughout
 the prospectus that since July 19, 2023, you do not transact, or make
offers to transact
 with your customers, in any crypto assets except Bitcoin. However, your
website (at
 https://athenabitcoin.com/how-to-buy) states that you "currently offer
Bitcoin,
 Litecoin, Ether/ETH and Bitcoin Cash (BCH)" for purchase through your
Athena
 ATMs. Additionally, the "Athena Plus" webpage on your website states
that, "Athena
 Plus-approved clients have access to buy and sell the following digital
currencies:
 Bitcoin (BTC/XBT), Ethereum (ETH), and Litecoin (LTC). More assets might
be
 available upon request." Please advise as to whether you transact, or
make offers to
 transact, with your customers in crypto assets other than Bitcoin. Also,
please revise
 to reconcile and/or clarify your disclosures, as appropriate.

 Please contact Rolf Sundwall at 202-551-3105 or David Irving at
202-551-3321 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Irene Paik at 202-551-6553 or David Lin at 202-551-3552 with any other
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Crypto
Assets
cc: Iwona J. Alami, Esq.
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