SecProbe.io

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

							September 20, 2005

Via U.S. Mail
Peter A. Wuffli
Chief Executive Officer
UBS AG
Bahnhofstrasse 45
CH-8098
Zurich, Switzerland

RE:		UBS AG
      Form 20-F for the fiscal year ended December 31, 2004
		File No. 1-15060

Dear Mr. Wuffli:

      We have reviewed the above filing and have the following
comment.  We have limited our review of your Form 20-F to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 20-F.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information, so that we may better understand your
disclosure.  Please be as detailed as necessary in your response.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone number
listed
at the end of this letter.

General

We note from publicly available sources that last year you were
fined
$100 million by the U.S. Federal Reserve as a penalty for engaging
in
USD banknote transactions with countries subject to sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control, including Cuba, Iran and Libya.  Please advise us
whether you have engaged or currently engage, directly or
indirectly,
in other transactions, including financing or credit arrangements,
in
or with Cuba, Iran and/or Libya.  If so, please briefly describe
for
us the nature of your operations and customer relationships in
each
country.  Advise us whether your customers include or have
included
the governments of these countries, or enterprises controlled by
the
governments of these countries.  In view of the fact that Cuba,
Iran
and Libya have been identified by the U.S. State Department as
state
sponsors of terrorism, and Cuba and Iran are subject to OFAC-
administered economic sanctions, please advise us of the
materiality
of your contacts with these countries, and give us your view as to
whether those contacts, individually or in the aggregate,
constitute
a material investment risk for your securityholders.

In preparing your response, please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
legislation requiring divestment from, or reporting of interests
in,
companies that do business with U.S.-designated state sponsors of
terrorism has been adopted by Arizona and Louisiana.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please file your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comment, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.
      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Frank Green
at
(202) 551-3522 if you have any questions about the comment or our
review.  You may also contact me at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Todd Shiffman
		Assistant Director
		Division of Corporation Finance

Peter A. Wuffli
UBS AG
September 20, 2005
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