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CORRESP
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CORRESP

 UBS

 UBS AG

Postfach

 8098 Zürich

Tel.+41-44-234 11 11

Corporate Center

 Group CFO Management

 Tom Naratil

Tel.+41-44-234 24 07

 Fax +41-44-234 21 00

tom.naratil@ubs.com

www.ubs.com

 Ms. Stephanie Ciboroski

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street, NE

 Washington DC 20549-1090

 30 September 2013

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, 2012

 Filed March 14, 2013

Form 6-K filed April 30, 2013

 Responses dated
February 28, 2013 and April 29, 2013

 File No. 001-15060

Dear Ms Ciboroski:

 We respectfully submit the responses set
forth below to the Comment Letter dated September 5, 2013 (the “Comment Letter” and individually or collectively “Comments”) from the Staff of the Securities and Exchange Commission relating to (a) Form 20-F for the
Fiscal Year Ended December 31, 2012, filed March 14, 2013 (the “2012 Form 20-F”) and (b) Form 6-K filed April 30, 2013 (the “Q2 2013 Form 6-K”) of UBS AG (“UBS”). For your convenience, we have set
out the text of each Comment contained in the Comment Letter, followed by our response.

 Form 20-F for the Fiscal Year Ended December 31, 2012

 General

 Comment 1

Please tell us about any contacts with Syria, Sudan and Cuba since your letters to us dated February 18, 2011 and June 6, 2011. We note that
Byblos Bank and Mashreq Bank list you as a correspondent bank and Byblos Bank has offices and branches in Syria and Sudan, and Mashreq Bank has offices and branches in Sudan. We note that your website lists the Caribbean as one of your markets, and
Cuba is in the Caribbean. As you know, Syria Sudan and Cuba are designated by the U.S. Department of State as state sponsors of terrorism, and are subject to U.S. economic sanctions and export controls. Please describe to us the nature and extent of
your past, current, and anticipated contacts with Syria, Sudan and Cuba, whether through subsidiaries, affiliates, customers, or other

 UBS AG is a public company
incorporated with limited liability in Switzerland domiciled in the Canton of Basel-City and the Canton of Zurich respectively registered at the Commercial Registry offices in those Cantons with Identification No: CH-270.3.004.646-4 and having
respective head offices at Aeschenvorstadt 1, 4051 Basel and Bahnhofstrasse 45, 8001 Zurich, Switzerland and is authorised and regulated by the Financial Market Supervisory Authority in Switzerland. Registered in the United Kingdom as a foreign
company with No: FC021146 and having a UK Establishment registered at Companies House, Cardiff, with No: BR 004507. The principal office of UK Establishment: 1 Finsbury Avenue, London EC2M 2PP. In the United Kingdom, UBS AG is authorised by the
Prudential Regulation Authority and subject to regulation by the Financial Conduct Authority and limited regulation by the Prudential Regulation Authority. Details about the extent of our regulation by the Prudential Regulation Authority are
available from us on request.

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 2
 of 13

direct or indirect arrangements. Your response should describe any products or services you have provided to Syria, Sudan or Cuba directly or indirectly, and any agreements, commercial
arrangements, or other contacts with the governments of Syria, Sudan and Cuba or entities controlled by those governments.

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

 Comment 2

 Please
discuss the materiality of any contacts with Syria, Sudan or Cuba described in response to the foregoing comment, and whether those contacts constitute a material investment 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 the 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. 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 Syria, Sudan and Cuba.

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

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 3
 of 13

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

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 4
 of 13

 Risk management and control – Credit risk, page 136

Exposures to selected Eurozone countries, page 150

Comment 3

 We note the response to comment 18 in your
response letter dated February 28, 2013. As previously requested, please revise your disclosure in future filings to quantify the amount of indexed or tranched purchased credit derivatives included in your tabular disclosure.

The amount of Trading inventory Net long per issuer exposure included in the referenced tabular disclosure that arises from multi-name credit derivatives is
insignificant in the context of the current total exposure. If this amount becomes material in future filings, we will revise our quantitative disclosure accordingly.

Notes to the consolidated financial statements

Note 23 – Provisions and contingent liabilities, page 375

Comment 4

 We note the response to comment 5 in your
response letter dated April 29, 2013. Please revise your disclosure in future filings to quantify the portion of your restructuring provisions related to onerous lease contracts versus the portion related to severance costs. Further, please
consider disclosing personnel related provisions as a separate class from onerous lease provisions in future filings to the extent that the liabilities or changes in the liabilities become material.

Starting with our Q3 2013 Form 6-K, we will quantify the portion of the restructuring provision related to onerous lease contracts and the portion related to
severance costs. To the extent that the liabilities or changes in the liabilities for these portions become material, we will consider disclosing them as separate classes in future filings.

b) Litigation, regulatory and similar matters, page 375

Comment 5

 We note the response to comment 8 in your
response letter dated February 28, 2013. We also understand from our conference call on April 4, 2013, that you are able to determine the expected timing of outflows of economic benefits in some circumstances. This fact should be disclosed
along with the expected timing of any outflows of economic benefits for your litigation and regulatory matters provision class for which you are able to make such an estimate, as well as information regarding the amount of your provisions covered by
such expected timing disclosure. Please provide us with your proposed disclosure, and tell us whether disaggregation of such disclosures by business division is practicable.

We are able to estimate the expected timing of outflows in limited circumstances, such as when we have entered into a settlement agreement and the related
outflow is scheduled to occur on a later date or in installments on several dates. In the overwhelming majority of cases, as we have stated in the introduction to our litigation note and in response to previous SEC Comments, there are too many
unknown factors to make such a determination. These include whether a matter will be settled, how long settlement negotiations would take to reach a conclusion, the timing and outcome of judicial decisions, the likelihood of appeal by UBS or by

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 30 September 2013

 Page
 5
 of 13

plaintiffs and whether an appeal would have the effect of staying the enforcement of a judgment. By aggregating the expected outflows where we are able to estimate timing, in principle we
could make a statement such as:

 With respect to certain litigation, regulatory and similar matters as to which we have established
provisions, we are able to estimate the expected timing of outflows. Of the aggregate amount of the expected outflows for which we are able to estimate expected timing, we estimate [approximately half/one-third/ …] to occur [over the next
             months], and the remainder to occur [over the next              to
             months].

 We do not, however, believe such disclosure would be useful to
investors, and there is an irreducible risk that it could be over-interpreted and misunderstood. Such outflows have not in the past been material in the context of our extremely high level of liquidity and with a Basel III liquidity coverage ratio
of 114% and a management liquidity coverage ratio of 160% as of 30 June, 2013, we have substantial liquidity available to meet numerous outflows, including those related to contingent liabilities. We believe that it is neither meaningful nor
helpful for investors to consider the immaterial effect of the timing of these outflows, as opposed to potentially important effects on profits or losses, capital ratios and (where applicable) reputation or business strategy. For this reason, we
propose to provide the requested disclosure only where the amount of the expected outflows as to which timing is estimable may be material to our liquidity position. So long as we believe that the effect on our liquidity is clearly immaterial, we
propose the following disclosure:

 With respect to certain litigation, regulatory and similar matters as to which we have established
provisions, we are able to estimate the expected timing of outflows. However, the aggregate amount of the expected outflows for those matters for which we are able to estimate expected timing is immaterial relative to our current and expected levels
of liquidity over the relevant time periods.

 Comment 6

We note the response to comment 3 in your response letter dated April 29, 2013 as well as your responses to comments 21 and 22 in your response letter
dated September 10, 2012. Please revise your disclosure in future filings to clearly describe how you evaluate whether both a provision and a contingent liability can arise from the same set of circumstances and clearly indicate that, with the
exception of certain limited situations, you believe these to be mutually exclusive concepts.

 Starting with our Q3 2013 Form 6-K, we will expand our
disclosure as follows (additional wording in italics):

 The Group makes provisions for such matters brought against it when, in the
opinion of management after seeking legal advice, it is more likely than not that the Group has a present legal or constructive obligation as a result of past events, it is probable that an outflow of resources will be required, and the amount can
be reliably estimated. If any of those conditions is not met, such matters result in contingent liabilities. Consequently, a matter arising from a single set of circumstances results in either a provision or a contingent liability, but not both,
except in limited cases (for example, where two separate matters arise from the same set of circumstances).

CONFIDENTIAL TREATMENT REQUESTED BY UBS AG

UBS AG

 Form 20-F for the Fiscal Year Ended

 December
31, 2012 Filed March 14, 2013

 Form 6-K filed April 30, 2013

Responses dated February 28, 2013 & April 29, 2013

 File No.
001-15060

 16 September 2013

 Page
 6
 of 13

 Comment 7

We note your disclosure at the top of page 376 explaining the reasons that you do not believe an aggregate estimate for your litigation, regulatory and
similar matters as a class of contingent liabilities is practicable. Given the response to comment 22 in your response letter dated September 10, 2012 that you are able to estimate the possible financial effects beyond the level of current
reserves established for certain cases but not others, we believe that this fact should be disclosed along with your estimate of the possible financial effects, which may be aggregated for all of the litigation matters for which you are able to make
such an estimate. Such aggregated disclosure should mitigate your concern that providing these estimates could seriously prejudice your position in these matters. Alternatively, and if true, you could include a statement that the possible financial
effects beyond the level of current reserves established would not have a material impact on your statement of financial condition, operations and cash flows. Please provide us with your proposed disclosure, and tell us whether aggregation of such
amounts by business division is practicable.

 As you have noted, we have explained in our litigation note the reasons for our conclusion that it is
not practicable to provide an aggregate estimate of the possible financial effects of litigation, regulatory and similar matters as a class of contingent liabilities. For certain individual cases, such an estimate would be possible but for most
if not all cases its disclosure would be seriously prejudicial. As you suggest, this risk may be mitigated by presenting an aggregate disclosure of the total estimate for all matters for which such estimation is practicable, provided that we do
not specify which matters are included or excluded. While such an estimate would likely be practicable, the possibility of a serious prejudicial effect would be magnified if we were to disclose a breakdown of such an aggregate estimate by
reporting segment. Certain segments are subject to only one or a very small number of major cases, a fact that will be made very apparent if we provide a divisional breakdown for the significant matters as your Comment 8 suggests.

Although it is possible to make the suggested aggregate disclosure at Group level, we continue to believe that this could be misconstrued by investors,
analysts, or other users (such as journalists). We would have to disclose that the estimate pertains to a subset of matters to which we are exposed, but it would not be possible to provide a meaningful indication of the scope or significance of
the excluded subset, which would likely include many of our potentially more significant matters. Users could falsely assume (despite including cautionary wording) that certain matters are within (or excluded from) the scope of the disclosed
estimate. It is important to note that certain analysts and journalists have expressed their own views concerning the exposure of UBS and other financial institutions to significant matters such as RMBS/loan putbacks and LIBOR. While we do
not necessarily agree with the assessments or the methodologies employed in the analyses that have been published, we are concerned that our disclosure of an aggregate estimate covering an unspecifi