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 Athena Bitcoin Global

 800 NW 7th Avenue,

 Miami, Florida 33136

 April 10, 2025

 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:
 Rolf Sundwall, Staff Accountant (202) 551-3105

 David Irving, Staff Accountant (202) 551-3321

 Irene Paik, Staff Attorney (202) 551-6553

 Sandra Hunter Berkheimer at (202) 551-3758

 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

 Amendment No. 4 to Registration Statement on Form S-1 Filed November 13, 2023

 Amendment No. 5 to Registration Statement on Form S-1 Filed January
 12, 2024
 Amendment No. 6 to Registration Statement on Form S-1 Filed February
 11, 2024

 File No. 333-262629

 Dear Ms. Paik:

 Athena Bitcoin Global (the
" Company ") confirms receipt of the letter dated March 10, 2025, 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.7 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. 6 to Registration Statement on Form
S-1 General

 Prospectus Summary

 Company Summary, Page 12

 1.
 We note your disclosure at page 13 and throughout the prospectus regarding the modifications to El Salvador's Bitcoin Law as of January 29, 2025 and that the Government of El Salvador is "stepping back from its involvement in Chivo Wallet." We also note your statement on page 33 that you "do not foresee a negative impact" from this legislative change. Please revise to explain in greater detail your reasons for this assessment. Also, please expand your disclosure to clarify the government's plans with respect to the Chivo Wallet.

 RESPONSE:

 In response to Staff's
comments, we have revised and expanded our disclosure on pages 13 and 33-35 of the Amendment No. 7 to provide further clarification and
detailed explanation of our statements. Specifically, with respect to your comment regarding our disclosure on page 13 under the heading
"White Label Services" and throughout our Prospectus, we have added the following statements:

 "The government is also stepping back from
its involvement in Chivo Wallet, the state-backed digital wallet, by either transferring it to private sector management or terminating
the program, as part of the country's agreement with the International Monetary Fund. We believe this development may open opportunities
for private companies (including the Company) to fill any service gaps left by the government's reduced role. We have assessed the
legislative changes and the Chivo transition, and do not foresee a negative impact on our business, in part because our existing ATM operations
and customer base in El Salvador are expected to continue without disruption. There is no assurance that our assessment may not change
depending on any future legal, political or economic changes in El Salvador."

 United States Securities and Exchange Commission

 April 10, 2025

 Page 2

 "…six articles of the Bitcoin Law
were modified and three others were repealed as of January 29, 2025. Under the new rules, Bitcoin is no longer considered "currency,"
though it remains "legal tender." Another change makes using Bitcoin entirely voluntary. Previously, the law mandated that businesses
accept Bitcoin for any goods or services they provided. Additionally, Bitcoin can no longer be used to pay taxes or settle government
debts. These changes are not expected to harm our operations because our Bitcoin ATM services in El Salvador do not depend on mandatory
Bitcoin usage; rather, they cater to organic consumer demand. Even under the new voluntary directive, Bitcoin remains legal tender, and
we believe demand for Bitcoin transactions will continue to be driven by individuals who choose to use Bitcoin. Our role as an ATM operator
for Chivo remains unchanged whereby we continue to manage the Bitcoin ATMs on the government's behalf under our fixed-fee service
arrangement, and this service is unaffected by whether Bitcoin use is voluntary or mandatory."

 With respect to your comment
regarding our disclosure on page 33 in the Prospectus, we have added the following statements in "Risk Factors Related to Our Operations
in El Salvador" on pages 33-35:

 "Six articles of the Bitcoin Law were modified,
and three others were repealed as of January 29, 2025. Under the new rules, Bitcoin is no longer considered "currency,"
though it remains "legal tender." Another change makes using Bitcoin entirely voluntary. Previously, the law mandated that
businesses accept Bitcoin for any goods or services they provided. Additionally, Bitcoin can no longer be used to pay taxes or settle
government debts. These changes are not expected to harm our operations because our Bitcoin ATM services in El Salvador do not depend
on compulsory Bitcoin usage; rather, they cater to organic consumer demand. Even under the new voluntary directive, Bitcoin remains legal
tender, and we believe demand for Bitcoin transactions will continue to be driven by individuals who choose to use Bitcoin. Our role as
an ATM operator for Chivo remains unchanged whereby we continue to manage the Bitcoin ATMs on the government's behalf under our
fixed-fee service arrangement, and this service is unaffected by whether Bitcoin use is voluntary or mandatory.

 The government is also stepping
back from its involvement in Chivo Wallet, the state-backed digital wallet, by either transferring it to private sector management or
terminating the program, as part of the country's agreement with the International Monetary Fund. We believe this development may
open opportunities for private companies (including the Company) to fill any service gaps left by the government's reduced role.
We have assessed the impact of the legislative changes and the Chivo transition and do not foresee a negative impact on our business,
in part because our existing ATM operations and customer base in El Salvador are expected to continue without disruption. There is no
assurance that our assessment may not change depending on any future legal, political or economic changes in El Salvador."

 Please see also our disclosure on page 62 under the heading "White
Label Services", page 95 under the heading "The Business – Expansion of Business Operations in El Salvador" and
on page 96 "Business Operations" under the heading in the same section.

 Business Strategies, Page 14

 2.
 In the last paragraph on page 15, you disclose that "[t]he Company has developed and has started rolling out the Athena Bitcoin Affiliates Program which provides Bitcoin ATM operators with a turnkey solution, offering industry-leading software, compliance support, cash management, and marketing services to streamline operations and maximize profitability." Please revise to describe this affiliate program in greater detail, including the material terms thereof and any future milestones.

 RESPONSE:

 In response to Staff's
comments, we have revised our disclosure in the Amendment No. 7 on pages 15 and 16 to provide the detailed and comprehensive description
of the Company's affiliate program. Specifically, we have added the following statements:

 "Also, the Company has developed and has
started rolling out the Athena Bitcoin Affiliates Program which provides Bitcoin ATM operators with a turnkey solution, offering industry-leading
software, compliance support, cash management, and marketing services to streamline operations and maximize profitability. This turnkey
solution is for participating independent Bitcoin ATM operators ("Affiliates") who will be able to leverage the Company's
established platform and services to manage their own Bitcoin ATMs more efficiently. The material terms of the program include:

 United States Securities and Exchange Commission

 April 10, 2025

 Page 3

 ·
 Services Offered: Affiliates receive access to our proprietary ATM software platform (including regular updates and maintenance), compliance support (such as anti-money laundering (AML) and "know your customer" (KYC) procedures developed by the Company), cash management guidance (e.g. armored transport coordination and vaulting services), and marketing support to help drive customer traffic to their ATMs.

 ·
 Fee Structure: Affiliates are charged a monthly service fee, or they participate in a revenue share arrangement (a percentage of transaction revenues) with the Company in exchange for the above services. The exact terms may vary by affiliate contract, but generally the Company's compensation is tied to the affiliate's transaction volume (revenue-sharing) and/or fixed fees for software licensing and support.

 ·
 Affiliate Obligations: Affiliates retain ownership of their ATMs but are required to adhere to our operational standards and compliance protocols. For example, Affiliates must implement the KYC/AML processes we provide and maintain their machines in accordance with the Company's guidelines. This ensures a consistent and secure experience across the extended network of ATMs.

 ·
 Future Milestones: The Affiliates Program was launched in late 2024 (pilot phase) and it is expected to be rolled out by mid-year 2025. A near-term milestone is to onboard additional ATM operators in key markets throughout 2025, which we believe will increase transaction volume and expand our brand presence without requiring significant capital expenditure by the Company. Our goal is to have a certain number of affiliate-operated ATMs live by the end of 2025. We also state that the program's progress will be evaluated by metrics such as the number of affiliate ATMs deployed, and the incremental revenue generated for the Company. No assurances can be made that we will be successful in achieving our goals with respect to future milestones."

 Risk Factors

 Our founders, single major shareholder, and director control
…, page 52

 3.
 We note your disclosure that your founders, together with a single major shareholder, beneficially own approximately 70.35% of your outstanding shares of common stock and may continue to control the company for the foreseeable future, including the outcome of matters requiring shareholder approval. Please revise to include comparable disclosure in the prospectus summary.

 RESPONSE:

 In response to Staff's
comments, we have included comparable disclosure in the Prospectus Summary under the heading "Risk Factors Associated with our Business"
on page 17 of the Amendment No. 7 to provide as follows:

 "Our founders together
with a single major shareholder, beneficially own approximately 70.35% of our outstanding shares of common stock. As a result, such individuals
will, for the foreseeable future, have the ability, if acting together, to control the election of our directors and the outcome of corporate
actions requiring shareholder approval under Nevada law. This concentration of voting power and control could have a significant effect
in delaying, deferring, or preventing an action that might otherwise be beneficial to our other shareholders. See "Management
and Certain Security Holders" for further discussion of the Board of Directors' structure and principal shareholders'
agreements."

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

 White Label Service, Page 62

 4.
 We note your disclosure on page 62 that you operate ATMs on behalf of the Government of El Salvador. We also note your disclosure on page 35 that the Government of El Salvador, through Chivo, operates the Chivo digital wallet. To the extent information is reasonably available, please revise to clarify:

• who holds the private keys relating to the crypto assets that are sold to end users from the Chivo ATMs (i.e., the end users' Chivo wallets); and
• how the private keys relating to such crypto assets are held (i.e., hot or cold storage).

 United States Securities and Exchange Commission

 April 10, 2025

 Page 4

 RESPONSE:

 In response to Staff's
comments, we have expanded our disclosure in the Amendment No. 7 on page 62 under the heading "White Label Services" in Management
Discussion and Results of Operations section to clarify the custody of crypto assets dispensed through the Chivo-branded ATMs, by including
the following additional statements to read as follows:

 "When a user purchases Bitcoin from a Chivo-branded
ATM, the ATM delivers the Bitcoin to the address selected by the user. This may be a Chivo wallet or any other wallet address, including
a non-custodial wallet.

 ·
 Holder of Private Keys: If 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. The Chivo wallet is a custodial wallet, meaning the end user does not have direct access to the private keys. In that scenario, the Government (or its designated Chivo wallet operator) has control over the crypto assets after delivery.

 However, users are not required to use a Chivo
wallet. If the user inputs a non-custodial wallet address, the Bitcoin is delivered directly to that wallet, and the user retains sole
control of the associated private keys. In all cases, regardless of the destination address, the Company never holds or has access
to the private keys for Bitcoin purchased by users at the ATMs. Our role is strictly limited to operating the ATM infrastructure and facilitating
the transaction; we do not have custody or manage digital assets on behalf of users.

 ·
 Method of Key Storage (Chivo Wallets): For transactions involving delivery to Chivo wallets, whereby the Company is not the custodian and does not have access to the Chivo wallet infrastructure, it is our understanding that the Government of El Salvador uses a combination of hot wallets (for real-time liquidity and immediate delivery) and potentially cold or multi-signature storage for operational security. Because transactions through Chivo ATMs require near-instantaneous delivery, the Chivo system maintains hot wallet liquidity to fulfill those transactions. The Company does not oversee or participate in the management of these storage practices.

 The Government of El Salvador has title to the
private keys to the crypto assets. However, the Company acts as the custodian for the cash in the ATM machine as well as cash that is
in-transit."

 The Business

 Athena Bitcoin ATM, page 92

 5.
 We note your response to prior comment 9 that you have revised your disclosure to indicate, among others, that your hot wallets are maintained by BitGo Trust Company, Inc., a third-party custodial service. However, we are unable to locate responsive disclosure and reissue the comment. Additionally, your disclosure on page 93 that your "hot wallets are maintained by the staff of the Company" and "[t]he Company does not utilize any third-party custodial services for the hot wallets" appears inconsistent with your response. Please clarify throughout the prospectus, as appropriate, whether you self-custody your or your customer's crypto assets and/or utilize a third-party custodian in this regard. Also, please disclose the material terms of any agreement you have with a third-party custodian and file the same as an exhibit to your registration statement, if required by Item 601 of Regulation S-K.

 RESPONSE:

 In response to Staff's
comments, we have revised our disclosure (Amendment No. 6 – page 93) on page 90 of the Amendment