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Athena Bitcoin Global

800 NW 7th Avenue,

Miami, Florida 33136

November 13, 2023

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Marc Thomas, Staff Accountant (202)
    551-3452

    Robert Klein, Staff Accountant (202) 551-3847

    David Lin, Staff Attorney (202) 551-3552

    J. Nolan McWilliams at (202) 551-3217

    Re:
    Athena Bitcoin Global

    Registration
        Statement on Form S-1

        Filed February 10, 2022

    Amendment No. 1 to Registration Statement on Form S-1

    Filed March 17, 2022

    Amendment
        No. 2 to Registration Statement on Form S-1

Filed May 16, 2022

    Amendment No. 3 to Registration Statement on Form S-1

        Filed June 24, 2022

    File No. 333-262629

Dear Mr. Lin:

Athena Bitcoin Global (the
“Company”) confirms receipt of the letter dated August 17, 2022, from the staff (the “Staff”) of
the Securities and Exchange Commission (the “Commission”) with respect to the above-referenced filings. We are responding
to the Staff’s comments in this letter and are contemporaneously filing Amendment No. 4 to Registration Statement on Form S-1 (the
“Amendment”). The Staff’s comments are set forth below, followed by the Company’s response:

Amendment No. 3 to Registration Statement on Form S-1

General

1. We note that beginning on page 40 the Company includes accounting analyses that we requested for
                                the purpose of facilitating our evaluation of the Company’s disclosure and not for the purpose
                                of inclusion in your filing. See for example June 24, 2022 response 10 and May 16, 2022 response 8. We
                                note that those analyses may not be suited to exposition in the Form S-1 in the manner undertaken. For
                                example, one or more of those discussions appears to be incomplete in its analysis and in its articulation
                                of the rights and obligations of the parties to the transactions to which the discussions apply. We also
                                note that some of the discussions use accounting terms incorrectly (e.g., performance obligation) and
                                its placement in MD&A appears to lack the appropriate context necessary to understand the discussion.
                                Please consider making substantial revision to your Form S-1 to include appropriate, fulsome disclosure
                                in an appropriate context. For example, the business section should include for each material type of
                                transaction, product, or service offering, including those identified in Note 3 on pages F-18 and F-50,
                                disclosure of the material terms of those transactions, products and service offerings; the financial
                                statements should include a description of the material rights and obligations of the contracts and your
                                accounting policies for each of them, as distinguished from the analyses you created to support them;
                                and MD&A should identify the critical accounting estimates that underlie the accounting for those
                                transactions and discuss why each critical accounting estimate is subject to uncertainty, how much each
                                estimate and/or assumption has changed over the relevant period, and sensitivity analysis of the reported
                                amount to the methods, assumptions and estimates underlying its calculation.

    United States Securities and Exchange Commission

November 13, 2023

Page 2

RESPONSE:

In response to Staff’s comments, we have amended
our disclosure in the Amendment. Examples of the changes made include the following:

 · The
                                            MD&A disclosures related to revenue recognition policies have been simplified. Information
                                            regarding the application of ASC 606 to our revenue sources has been added to the “Critical
                                            Accounting Policies and Estimates” section of the MD&A as well as both financial
                                            statements. The other disclosures relating to the application of ASC 606 have been removed.
                                            This will allow users to have appropriate context in regard to our revenue recognition policies.

 · The
                                            MD&A Critical Accounting Policies and Estimates revenue recognition section has been
                                            broken up into four sections.

Recurring Revenue

 o ATM
                                            Bitcoin Sales

 o Athena
                                            Plus (OTC) sales

 o White-Label
                                            Service

Ancillary Revenue

    o
    Development of the Chivo Ecosystem

    Each section includes appropriate language related to ASC 606 application, including the revenue
    recognition process, identification of the customer, duration of the contract, promises goods or services, performance obligations,
    nature of the consideration, material right consideration, transaction price and when control is transferred.

    ·
    We do not believe that there are significant estimates,
    outside of the identification of performance obligations, involved in our revenue streams given the nature of our revenue contracts
    and transaction fees.

    ·
    The audited consolidated financial statements and
    unaudited condensed financial statements have more in-depth disclosures regarding the application of ASC 606 to the revenue streams,
    including the revenue recognition process, identification of the customer, duration of the contract, promises goods or services,
    performance obligations, nature of the consideration, material right consideration, transaction price and when control is transferred.

    ·
    The Business Section has been updated to discuss revenue
    for the material streams in a more fulsome manner.

    ·
    We have included more disclosure regarding estimates.
    There are no areas that require a sensitivity analysis given the nature of our critical estimates.

2. As a follow-up to the preceding comment and in order to facilitate our
                                evaluation of your last response and your accounting policies, please revise your financial statement
                                revenue recognition accounting policy note to clearly address the following points for each revenue stream
                                identified in the disaggregated revenue disclosure in Note 3 on page F-18 and in Note 3 on page F-50
                                and for each material product and service offering:

 a who is your customer (or customers) as that term is used in ASC 606;

 b what is the duration of the ASC 606 accounting contract and why;

    United States Securities and Exchange Commission

November 13, 2023

Page 3

 c what are the promised goods or services;

 d what are the Company’s performance obligations;

 e what is the consideration specified in the contract (including whether the consideration
                   is fixed or variable, and if variable, whether it is constrained);

 f what is the ASC 606 transaction price; and

 g when control of the promised good or service transfers to the customers and how revenue
                   is recognized (e.g., at a point in time or over time).

RESPONSE:

We have included discussion for the items identified
above for each revenue stream in the audited consolidated financial statements and the unaudited condensed financial statements (pages
F-1 through F-____ of the Amendment).

Risk Factors

Our failure to safeguard and manage our crypto assets..., page
19

3. We note your disclosure that as of March 31, 2022 you were responsible for safeguarding $286 thousand
                                in crypto assets, all in the form of Bitcoin, for users of your discontinued BitQuick platform. Please
                                revise your disclosure to clarify what you mean by “safeguarding” and to discuss in greater
                                detail your practices for safeguarding these crypto assets. In this regard, please revise your disclosure
                                to clarify whether you are custodying Bitcoin for these users and if you are safeguarding keys for users,
                                as discussed in your response to comment 10. If so, please revise to explain your custodying practices
                                and how you safeguard the keys.

RESPONSE:

In response to the Staff's comments, please note that
the Company does not act as a custodian for any crypto assets.

For Bitcoin ATM Sales and Athena Plus, we hold title
to the private key until the transaction is complete. At that point, the customer obtains the crypto asset through the crypto asset's
blockchain.

For the white-label service, the wallet and crypto assets
that are connected to the ATM is the property of the government of El Salvador.

Please also note that Bitquick is currently an immaterial
revenue stream which was discontinued in 2021. We believe that the liability and revenue for Bitquick is immaterial. We have removed
references to Bitquick in the Amendment.

4. We note your response to comment 15 in which you disclose that you assume
                                the risk of loss for funds used in the operation of the Chivo branded ATMs while those funds are in transit
                                and that you do not believe that you are safeguarding in relation to your activities for the government
                                of El Salvador. Please revise your disclosure to identify the specific funds that you assume the risk
                                of loss for while those funds are in transit, provide greater details regarding your role and responsibilities,
                                including what you mean by “in transit,” and tell us how you have determined that you are
                                not custodying those assets. Please also revise your disclosure to identify the cash logistics companies
                                that you have contracted with and explain their role(s) in greater detail.

    United States Securities and Exchange Commission

November 13, 2023

Page 4

RESPONSE:

In response to the Staff’s comments, please note
that the Company is responsible for loading and unloading cash from the ATMs. One of the contractual requirements governing the white-label
service is that any cash logistics company utilized to perform this service must be insured.

The Company utilizes a third-party licensed and insured
cash logistics company to securely transfer these funds, complying with the contractual requirements. Any losses of cash in-transit
will be compensated by the cash logistics insurance company. However, as noted in the contracts, the Company has risk of loss until the
cash is in an account controlled by the government of El Salvador.

The Company meets the definition of a custodian given
the legal risk of loss remains with the Company in the contracts that govern the relationship between the Company and the government
of El Salvador. Therefore, we will adjust our financials by recording cash and an offsetting liability for cash in-transit. We will also
identify the cash logistics companies utilized by the Company.

Please note that there are circumstances where the Company
is responsible for crypto assets in transit, per the terms of the applicable service agreement. However, given the inherent nature of
crypto assets, this is governed by the respective crypto asset’s blockchain. Blockchains typically transmit crypto assets in less
than an hour, resulting in no material balances being in-transit as of each reporting date. The Company is not liable for sending the
incorrect amount or using the wrong address. The El Salvadoran government is liable for any incorrect amounts sent and the users of the
ATM are responsible if they transmit the crypto assets to the wrong crypto address.

Management's Discussion and Analysis of Financial Condition
and Results of Operations Revenue Recognition for the Sale of IP to Government of El Salvador, page 40

5. We continue to evaluate response 6 and your accounting for the sale
                                or license of IP to the government of El Salvador. We note that the disclosure on page 6 of your filing
                                identifies what appear to be a number of promises that you appear to have made in your contract with
                                the government of El Salvador, including, but not limited to those listed below, however the material
                                terms of this contract are not disclosed in your financial statement footnotes discussing the contract
                                (see pages F-19 and F-51) and your accounting for this contract is not clearly evident from your revenue
                                recognition accounting policy in Note 3 to your interim and annual financial statements. For example,
                                it remains unclear whether this is an all-inclusive list of the promised goods and services you agreed
                                to provide; what some of the descriptions below mean, (e.g. “subsequent improvements”); what
                                constitutes the ASC 606 contract (e.g., whether legal contracts are required to be combined for purpose
                                of the determining the ASC 606 accounting contract); what the ASC 606 performance obligations are and
                                why; what the ASC 606 transaction price is and how you allocated it to the performance obligations; and
                                the pattern of recognition for each performance obligation. Please revise your financial statement footnotes
                                to disclose the promised goods and services in this contract and your accounting for the contract. Please
                                provide us your accounting analysis.

 a installing and operating ATMs;

 b installing POS terminals;

 c maintaining the existing software infrastructure supporting the operation of the
                   ATMs;

 d hardware maintenance of the ATMs;

 e cash logistics;

 f customer support;

 g develop and maintain a Bitcoin platform (Chivo Ecosystem) to support the Chivo digital
                   wallet;

 h provide the software for the Chivo digital wallet, comprising both the software that
                   runs on mobile smartphones and the software that runs on servers, with the functionality described on page 6;

 i deliver “subsequent improvements;”

 j assist the government’s secondary provider; and

 k “[p]arts of the contract related to data retention security, analysis and reporting
                   remain in effect as of the time of this prospectus.”

    United States Securities and Exchange Commission

November 13, 2023

Page 5

RESPONSE:

In response to Staffs comments, please note that the
contracts that the Company has entered into with the government of El Salvador represent obligations for multiple revenue sources. These
revenue sources have separate promises, as defined in the contracts and are related to separate performance obligations. The discussion
in the MD&A and Financial Statements have been updated to reflect the promises, how we determined performance obligations and the
other aspects of ASC 606 that you refer t