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CORRESP
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 Athena Bitcoin Global

 1 SE 3rd Avenue, Suite 2740

 Miami, Florida 33131

 May 5, 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
 Amendment No. 7 to Registration Statement on Form S-1 Filed April 10,
 2025
 File No. 333-262629

 Dear Ms. Paik:

 Athena Bitcoin Global (the
" Company ") confirms receipt of the letter dated April 23, 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. 8 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. 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.

 1

 United States Securities and Exchange Commission

 May 5, 2025

 Page 2

 RESPONSE:

 In response to Staff's
comments, we have revised the Risk Factor on page 29 of the Amendment No. 8, and provided the disclosure of the Company's insurance
policy with BitGo, including the name of the insurance carrier, the coverages provided by BitGo's insurance policy and the coverage
limits, to read as follows:

 "The theft, loss, or
destruction of private keys required to access any Bitcoin may be irreversible. If we are unable to access our private keys or if we
experience a hack or other data loss relating to our ability to access any bitcoin, it could cause regulatory scrutiny, reputational
harm, and other losses.

 Bitcoin is generally accessible
only by the possessor of the unique private key relating to the digital wallet in which the Bitcoin is held. While blockchain protocols
typically require public addresses to be published when used in a transaction, private keys must be safeguarded and kept private to prevent
a third party from accessing the Bitcoin held in the applicable wallet. To the extent that any of the private keys relating to our wallets
containing Bitcoin held for our own account or our users' private keys relating to their un-hosted wallets is lost, destroyed,
or otherwise compromised or unavailable, and no backup of the private key is accessible, we or our users will be unable to access the
Bitcoin held in the related wallet. Further, we cannot provide assurance that our or our users' wallets will not be hacked or otherwise
compromised. Cryptocurrency and blockchain technologies have been, and may in the future be, subject to security breaches, hacking, or
other malicious activities. Any loss of private keys relating to, or any hack or other compromise of, digital wallets used to store our
users' Bitcoin could adversely affect our users' ability to access or sell their Bitcoin, as well as result in loss of user
trust in us. As such, any loss of private keys due to a hack, employee or service provider misconduct or error, or other compromise by
third parties could hurt our brand and reputation, result in significant losses, and adversely impact our business. However, the Company
does not (i) custody Bitcoin purchased by customers, (ii) nor does it manage or have access to private keys belonging to customers' personal
(un-hosted) wallets (iii) nor does it hold private keys for users. Customers are solely responsible for their own wallets and private
keys. When a customer uses an Athena Bitcoin ATM to purchase Bitcoin, the Bitcoin is directly delivered to a wallet address provided
by the user (typically a mobile wallet app). These user wallets are "un-hosted" or self-custodied, meaning the users alone
control their private keys.

 The risk of loss or compromise
of private keys related to Bitcoin owned by the Company is mitigated by our use of a third-party custodian, BitGo Trust Company, Inc.
("BitGo") (a qualified custodian) who has been engaged to secure our digital assets. BitGo manages the private keys for digital
wallets holding Bitcoin owned exclusively by the Company (i.e., held for our own account). This means all Bitcoin held as inventory,
or held for operational liquidity by the Company, is secured by BitGo, which manages the corresponding private keys on our behalf. If
these keys were lost or compromised, BitGo's protocols, including secure backups and recovery processes, would mitigate this risk.

 BitGo provides multi-signature
wallet services and secure key management for the Bitcoin that the Company holds for its own account and for facilitating customer transactions.
By entrusting this function to BitGo, we add a layer of security and risk mitigation (given BitGo's expertise and insurance arrangements)
beyond what could be achieved with in-house custody.

 The Company has a standard service
agreement with BitGo under which BitGo safeguards the private keys and crypto assets that the Company deposits with it. 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). BitGo has and maintains insurance for custodial services through Lloyd's of London who provides
crime insurance coverage with a limit of $5,000,000 and specie insurance coverage with a limit of $250,000,000.

 United States Securities and Exchange Commission

 May 5, 2025

 Page 3

 A summary of the coverages
is listed below:

 SUMMARY OF SPECIE INSURANCE

 Coverage / Insuring Clauses:

 The Insurers shall indemnify the Insured
for Insured Loss occurring during the Period of Insurance which renders the Cryptocurrency contained at the associated Public Address
on the Blockchain unrecoverable as more fully described in the policy.

 Summary of Exclusions (all more
fully described in the policy):

 1) Theft or dishonesty by principal
shareholder, partner, director, or officer who is not a Designated Custodian: Designated Custodian means those appointed employees who
make up the Withdrawal Team as fully described to Underwriters.

 2) Loss from any act or default
of any partner, employee, director or officer of the Insured, controlling more than 5% of the Insured.

 3) Loss from the complete or
partial non-payment or default upon any loan.

 4) Loss from any trading.

 5) Loss or damage from Cryptocurrency
Private Keys where the Storage Media was or at any time prior, had been connected to the internet or any external network.

 6) Loss or damage to and/or resulting
from Cryptocurrency Private Keys which were not held on Storage Media and prior to the Storage Media being securely deposited at the
Designated Premises.

 7) Loss from network failure
of a cryptocurrency cryptographic protocol.

 8) Loss from acts of a designated
custodian occurring after the time any director or officer of the Insured first became aware of any act or acts of theft, fraud or dishonesty
of such designated custodian.

 9) Loss not discovered and notified
to insurers within thirty days after the policy expiration date.

 10) Consequential loss.

 11) Money laundering.

 12) War.

 13) Radioactive contamination.

 14) Mechanical breakdown.

 15) Terrorism.

 16) Sanctions.

 SUMMARY OF CRIME INSURANCE

 Coverage / Insuring Clauses:

 1) Employee Theft

 2) Premises

 3) Transit

 4) Third Party Computer and Funds
Transfer Fraud

 5) Legal Fees, Costs & Expenses

 United States Securities and Exchange Commission

 May 5, 2025

 Page 4

 Summary of Exclusions (all more
fully described in the policy):

 1) Loss resulting from fraud
of director except to the extent that the director is deemed to be an Employee and only applies to where they own 15% or greater of issued
share capital

 2) Loss caused by an Employee
if an directors or officers are aware of prior theft or fraud

 3) Loss of income or profit not
realized by the Assured.

 4) Loss of trade secrets, intellectual
property

 5) Loss due to the giving or
surrendering of physical Property in any legitimate exchange/purchase

 6) Any loss solely dependent
upon an inventory or a profit and loss computation.

 7) Indirect or consequential
loss of whatever nature

 8) War

 9) Radioactive contamination

 10) Arithmetical, accounting,
or computing errors or omissions

 11) Mechanical failure, breakdown,
programming errors, processing errors

 12) Circumstances or occurrences
noticed to prior policies

 13) Default of a loan

 14) Payments or withdrawals to
BitGo that are not settled

 15) Network failure of the cryptographic
protocol

 The following exclusions are
applicable to Insuring Clauses 2 (Premises) and 3 (Transit) only:

 1. Forged or Fraudulently Altered
or Counterfeit Property

 2. Loss or damage to Property
while in the mail

 3. Kidnap/Ransom/ Extortion

 4. Terrorism

 BitGo is
a qualified custodian regulated by the South Dakota Division of Banking, which provides assurance that our custodied assets are held
in a compliant manner."

 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.

 United States Securities and Exchange Commission

 May 5, 2025

 Page 5

 RESPONSE:

 In response to Staff's comments,
we have included our disclosure in the Amendment No. 8 on page 35 in the section "Risk Factors – Risks Related to Our Operations
in El Salvador" under the heading " Risks related to the custody of the private keys associated with the Chivo wallet system,
including any risk of loss or compromise of such private keys " by providing the following statements:

 "Risks related to the custody
of the private keys associated with the Chivo wallet system, including any risk of loss or compromise of such private keys.

 The Government of El Salvador (or
its designated Chivo wallet operator) retains custody of the private keys associated with the Chivo wallet system. The
Company's role is strictly limited to operating the ATM infrastructure and facilitating the transfer of cash from the ATMs to
the banks that Chivo transacts with. We do not have custody or manage Bitcoin on behalf of Chivo or its end users. Furthermore, the
Company does not have access to end users of the Chivo system. The end users who participate in the Chivo wallet system, also do not
have access to the private keys to the Chivo wallet. When the end user chooses to receive Bitcoins in the Chivo wallet}, the end
user agrees that the Government of El Salvador (or its designated Chivo wallet operator) retains custody of the private keys
associated with the wallet. Since the Company is neither the custodian of the private keys nor is the Company involved in the
transactions between the end users and Chivo, any compromise or loss of these private keys could adversely affect public confidence
in the Chivo wallet system, negatively affecting its reputation or brand, and consequently potentially reducing the number of
transactions conducted through Chivo-branded ATMs resulting in lowering associated management fees earned by the Company. However,
based on the Company's assessment, such loss or compromise of private keys associated with Chivo wallet system, would likely
have only limited potential impact on the Company's overall business because revenues from Chivo represent an insignificant
fraction of the Company's total operations and revenues. No assurance can be made that the impact of any reputational risk
will not be of a significant nature in the future.

 The Company entered into certain agreements
with the government of El Salvador, for the operation and management of the Chivo branded ATMs, however such contracts do not obligate
the Company to assume the risk of loss or compromise of private keys associated with Chivo wallet system."

 United States Securities and Exchange Commission

 May 5, 2025

 Page 6

 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.

 RESPONSE:

 In response to Staff's
comments, please be advised that the Company does not transact, or make offers to transact, with our customers in crypto assets other
than Bitcoin. Furthermore, we have reconciled our disclosure on our Athena Bitcoin website (at https://athenabitcoin.com/how-to-buy) with
our disclosure in the Amendment. Additionally, our statements on the Company's website regarding digital assets available for purchase
and sale on Athena Plus, have been reconciled and revised to be consistent with our disclosure in the Amendment.

 We trust that this response satisfactorily responds
to your request. Should you require further information, please contact our legal counsel Iwona Alami at (949) 760-6880.

 Very truly yours.

 By: /s/ Matias Goldenhorn

 Chief Executive Officer

 cc: Iwona Alami, Esq.