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    UBS AG

    Postfach

    CH-8098 Zürich

    Tel. +41-44-234 11 11

    www.ubs.com

Via EDGAR and messenger

Mr. Michael Seaman

Special Counsel

Division of Corporation Finance

United States Securities and Exchange

Commission

100 F Street, N.E.

Washington, D.C. 20549

February 18, 2011

UBS AG HAS CLAIMED CONFIDENTIAL TREATMENT OF PORTIONS OF THIS LETTER IN
ACCORDANCE WITH 17 C.F.R. §200.83

UBS AG

Form 20-F for the fiscal year ended December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

Dear Mr. Seaman:

We respectfully submit the responses set forth below to the comment letter dated January 18, 2011
(the “Comment Letter”) from the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) relating to (a) the annual report on Form 20-F for the fiscal year ended December 31,
2009 (the “2009 Form 20-F”), (b) the first quarter 2010 report on Form 6-K (the “Q1 2010 Form
6-K”), and (c) the second quarter 2010 report on Form 6-K (the “Q2 2010 Form 6-K) of UBS AG (“UBS”
or the “Company”). For your convenience, we have set out the text of each comment contained in the
Comment Letter, followed by our response. As you requested, we have included supplemental
information where applicable.

Reference is also made to an earlier comment letter from the Staff dated September 9, 2010 (the
“September Comment Letter”) with respect to the filings noted above. UBS responded to the
September Comment Letter on October 7, 2010. In a subsequent telephone call with the Staff related
to Comment 15 in the September Comment Letter, UBS undertook to include in our Annual Report on
Form 20-F for the year ended December 31, 2010, enhanced disclosure of our exposures to sovereign
debt issued by countries that have suffered market dislocation. We hereby confirm our intention to
include such enhanced disclosure.

General

1. It does not appear that you have filed “clean” opinions of counsel in connection with
your ongoing sales of linked notes under your shelf registration statement (File No. 333-
156695). Please advise us why “clean” opinions have not been filed, or if they have been
filed, where they are located.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 2 of 8

The validity opinions of Sullivan & Cromwell LLP (as to New York law) and Homburger AG (as to Swiss
law) filed as exhibits 5.1 and 5.3, respectively, to the referenced registration statement
contained conditions that reflected the fact that the opinions were written at a time when the
registration statement had not yet been filed or become effective, and the specific authorization
of any securities to be issued under the registration statement had not yet occurred. We believed,
based on advice of counsel and on our own experience with previous Form F-3 filings, that these
conditions were typical in opinions filed as Exhibit 5 to shelf registration statements, and we
continue to believe that our filing is consistent with long-standing and current market practice.

In order to file completely clean opinions, we would need to file separate opinions under both U.S.
and Swiss law at the time of each issuance under the registration statement. We do not believe
that it is standard market practice to do so, although we acknowledge that some less-frequent
issuers do so. In 2010, we completed about 230 separate takedowns under the registration
statement. We would ask the Staff to consider the substantial time and cost burdens involved in
preparing and filing both U.S. and Swiss opinions on a nearly daily basis for a frequent issuer
like UBS. Further, we believe that the constant stream of Forms 6-K put on the record will make it
much more difficult for investors to watch for filings containing truly important information about
UBS.

We understand that Sullivan & Cromwell and others are discussing with the Staff the best way to
address the Staff’s concern on this point, on UBS’s behalf and on behalf of other registrants. We
would ask that we be permitted to await the outcome of those discussions before agreeing to a
specific course of action.

2. We have received your response to comment 9 from our letter dated September 9, 2010 and
the related supplemental correspondence dated December 31, 2010. Our review is ongoing and
we may have further comments.

We await the outcome of completion of the Staff’s review of this item.

3. Please tell us about your contacts with Iran, Syria, Sudan and Cuba, countries subject to
U.S. economic sanctions and export controls and identified by the U.S. State Department as
state sponsors of terrorism, since your letters to us of November 16, 2005, April 20, 2006
and September 6, 2006. In this regard, we note the disclosure in your 20-F regarding your
operations in the Middle East, Africa and Latin America, and the disclosure in your 20-F for
fiscal 2007 that you decided to exit commercial and client business dealings with countries
including Iran and Sudan. Please discuss the nature and extent of your contact with these
countries, whether direct or through affiliates, partners, or other indirect arrangements.

UBS has no subsidiary or affiliate, employees or other physical presence in any of the Subject
Countries. *** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 3 of 8

UBS is a globally active financial institution and recognizes its obligations towards various
stakeholders, laws and regulations. During 2005, after conducting a careful evaluation of business
and risks, UBS adopted a global sanctions policy and decided to end business dealings on a
group-wide, global basis with a limited number of countries, including Iran, Cuba, Sudan, Myanmar,
North Korea, and — to a lesser extent — Syria (save for a limited number of permitted transactions
such as those for the United Nations and a limited number of certain other
international/humanitarian organizations). Our commitment to this policy is serious and forms part
of the corporate culture that starts at the top of the organization and runs all the way through
its operations. This decision required us to exit client relationships with individuals (except
Syrian nationals) and institutional clients domiciled in these countries, and no new or further
business has been undertaken since we began to implement our policy decision in 2005.
Implementation of this policy, including exiting relationships and implementing global systems and
controls, began in 2005 and was largely complete by the end of 2006.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

4. Please discuss the materiality of your contacts with Iran, Cuba, Syria or Sudan
described in response to the foregoing comment and whether those contacts constitute a
material risk for your security holders. You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets and
liabilities for the last three fiscal years and subsequent interim period. Also, address
materiality in terms of qualitative 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. As you may be aware, various state and
municipal governments, universities and other investors have proposed or adopted divestment
or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism. Your materiality analysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Iran, Cuba, Syria and Sudan.

*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 ***

We understand that a number of U.S. states and local governments have proposed or adopted
legislation requiring divestment from, or reporting of interests in, companies that do business in
certain countries. We further understand that this legislation is designed to restrict support of
business in sanctioned countries to enhance the effect of existing sanctions measures against the
current regimes of the countries in question. We believe that our implementation of our internal
sanctions policy is consistent with these goals.

5. Please also discuss the potential for reputational harm from your relationships with
third parties. For instance, we note from 2007 and 2008 news articles that you have provided
advisory or investment banking services to PetroChina, which has contacts with Iran, Syria,
Sudan and Cuba, and which acknowledges on both its website and in its most recent 20-F the
risk of adverse investor reaction to PetroChina because of the operations of its parent,
China National Petroleum Corporation, in all four countries, as well as its own operations
relating to those countries. In addition, we note from 2008 news articles that you
purchased a large block of Sinopec Shanghai PetroChemical, which acknowledges in its most
recent 20-F negative publicity and divestment of its stock because of its parent companies’
Sinopec Corp. and Sinopec Group operations in Iran, Syria, Sudan and Cuba. Please discuss
the significance to you of these types of relationships, and the potential for harm to your
reputation and share value to suffer as a result of your relationships with these companies.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 4 of 8

UBS continues to apply its internal sanctions policy to protect the firm’s reputation and ensure
compliance with the economic sanctions laws of the jurisdictions in which it does business. In
addition to recognizing applicable local sanctions restrictions, the policy applies a set of
sanctions restrictions consistent with the sanctions restrictions imposed by the United Nations,
European Union, United States and Switzerland. These business restrictions apply to any entity
that is UBS controlled.

While the existence of particular sanctions does not mean that all transactions involving parties
having connections to or with a particular country are prohibited, UBS is keenly aware of the
reputational risks that can accompany business activities connected to sanctioned parties. It
therefore employs risk-based, internal procedures to prevent its products and services from being
used to facilitate business with sanctioned parties. These internal restrictions may result in
UBS’s refusal of business, even if permissible under applicable law. UBS’s sanctions controls
continue to evolve, and emphasis on indirect sanctions risk has increased.

UBS assesses the reputational risk associated with business activity, including investment banking
activity, on a case-by-base basis. Decisions are highly dependent on circumstances and facts
available at a particular time. A decision to conduct business with a client in the circumstances
existent on one date does not mean that UBS would proceed with a similar transaction presented at a
later date. In reviewing a potential business proposal, UBS considers a variety of factors and
informational sources, taking particular note of those companies predominantly engaged in
sanctioned countries. These internal controls were employed in UBS’s careful consideration of its
participation in the 2007-2008 Petrochina A-share IPO listing on the Shanghai stock market. UBS
conducted a thorough review of available facts and proceeded after satisfying itself that its
services in furtherance of the IPO were supporting domestic projects in China, and not projects in
sanctioned countries. While UBS gave particular consideration to the fact that Petrochina’s
parent, CNPC, had activities in Sudan, it also observed that Petrochina was a separate corporation
with listings on the New York and Hong Kong stock exchanges that neither had operations in Sudan
nor derived any revenues from Sudan.

The reputational risk connected with an activity can depend in part on the regulations and guidance
provided by the office that administers the U.S. sanctions programs, the U.S. Department of the
Treasury’s Office of Foreign Assets Control. UBS has taken note of written OFAC guidance, made
available by industry groups, which outlines the circumstances under which U.S. persons’ minority
ownership of companies doing business with sanctioned countries is, in fact, permissible.

Sinopec Shanghai Petrochemical has not been sanctioned by the U.S. government. UBS has no control
or strategic participation in Sinopec Shanghai Petrochemical, which is ultimately majority-owned
and controlled by the Chinese government. UBS’s holdings of shares in Sinopec Shanghai
Petrochemical constitute a small percentage of issued shares and a small portion of UBS holdings.
*** CONFIDENTIAL TREATMENT REQUESTED UNDER RULE 83 *** UBS does not view this level of holdings as
material or potentially material to investors.

Exhibits, page 21

Exhibit 4.1

6. We note your response to our prior comment 1. Please address why you believe you are
not required to file the Deferred Prosecution Agreement in its entirety in light of
your obligations as a reporting company. In the alternative, please amend your Form 20-F to
file the agreement in its entirety or submit an application for confidential treatment
pursuant to Exchange Act Rule 24b-2.

    CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

    UBS AG

Form 20-F for the fiscal year ended

December 31, 2010

Form 6-K furnished May 4, 2010

Form 6-K furnished July 27, 2010

File Number 001-15060

    Page 5 of 8

When we filed our 2009 Annual Report on Form 20-F in March 2010, we believed that filing the
Deferred Prosecution Agreement (DPA) as an exhibit was required because the agreement itself was
material to UBS, and both (i) was to be performed in whole or in part on or after the date of the
filing, and (ii) was entered into not more than two years before the filing date. The DPA has five
exhibits — i.e., Exhibits A-E — four of which were included in our filing. We did not include
Exhibit E in our filing because Exhibit E was filed under seal by the Department of Justice and
remains under seal pursuant to an order (the “Seal Order”) issued in February 2009 by the United
States District Court for the Southern District of Florida in United States of America v. UBS AG,
Case No. 09-60033-CR, February 18, 2009 (S.D. FL.) in connection with that Court’s approval of the
DPA at that time. Absent the Seal Order, Exhibit E would have been included in the filing. In our
filing, we clearly disclosed its absence, and indicated in abbreviated form the reason.

By way of background, the DPA resolved a lengthy investigation by the Department of Justice, Tax
Division (“DOJ”) of UBS’s U.S. cross-border business. The DPA was presented to and approved by the
District Court on February 18, 2009. In connection with the execution of the DPA, DOJ filed a
one-count criminal information (the “Information”) charging UBS with conspiracy to defraud the IRS
through the operation of the U.S. cross-border business through which Swiss-based private bankers
allegedly assisted U.S. clients in evading their U.S. income tax obligations. The DPA had a
minimum term of 18 months, and contained a number of obligations that UBS had to fulfill in that
time, including completing its previously announced exit from its U.S. cross-border business. If
during that 18-month term, or any permitted extension, UBS fulfilled all of i