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August 14, 2023

Securities and Exchange Commission

Division of Corporate Finance

Office of Crypto Assets

100 F Street, NE

Washington, D.C. 20549

Attn: Ms. Bonnie Baynes, Mr. Mark Brunhofer, Mr.
Tyler Howes and Ms. Jennifer Gowetski

Re: Mercurity Fintech Holding
Inc.

Form 20-F for the fiscal
year ended December 31, 2022

Filed April 25, 2023

File No. 001-36896

Dear Ms. Bonnie Baynes, Mr. Mark Brunhofer, Mr.
Tyler Howes and Ms. Jennifer Gowetski:

Please find below our responses
to the questions raised by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
in its letter of comments dated July 17, 2023 (the “Comment Letter”) relating to the annual report on Form 10-K for
the year ended December 31, 2022, which was filed with the Commission by Mercurity Fintech Holding Inc. (the “Company”
or “we”) on April 25, 2023.

The Company’s responses
are numbered to correspond to the Staff’s comments. For your convenience, each of the Staff’s comments contained in the Comment
Letter has been restated.

Form 20-F for the fiscal year ended December
31, 2023

Item 5. Operating and Financial Review and
Prospects

D. Trend Information, page 70

    1.
    Please provide us proposed revised disclosure for page 70 to be
    included in future filings (including any potential amendment of this Form 20-F) to disclose the uncertainty and related impact to the
    company, including quantification, of the pending legal proceedings of intangible assets stored in out-of-control cold wallets, also referred
    to as the recovery proceeding, on pages F-3, F-42 and F-55. Also provide proposed revised disclosure for your related disclosure on page
    84 under "Legal Proceedings".

Response: The Company submits as follows its proposed revised
disclosure to be included in future filings.

“D. Trend Information (revised)

In late February 2022, the former acting Chief Financial
Officer Wei Zhu, who was also the Company’s former Co-Chief Executive Officer, and a former member and Co-Chairperson of the Board,
was taken away from the Company's office in Shenzhen, China for personal reasons to cooperate with the investigation conducted by Sheyang
County Public Security Bureau, Yancheng City, Jiangsu Province, People’s Republic of China. At the same time, Sheyang County Public
Security Bureau forcibly took away the safe belonged to the Company that stored the digital asset hardware cold wallet, and forcibly opened
the safe by destroying the lock thereto and seized the digital asset hardware cold wallet and all cryptocurrencies stored therein.

The book value of the Bitcoins and USD Coins stored in the
out-of-control wallet was $3,944,808 on December 31, 2022, and we verified that Bitcoins and USD Coins with a book value of $3,469,762
as of December 31, 2022 stored in the out-of-control wallet had been transferred to another unknown wallet.

The Company’s PRC law firm Deheng Law Office (“Deheng”)
has been representing the Company in our efforts to recover the wrongfully seized cold wallet and cryptocurrencies from the PRC’s
Public Security Bureau. On November 21, 2022, Deheng submitted the complaint and evidentiary materials to the Public Security Bureau according
to the Criminal Procedure Law and the Provisions on Procedures of Handling Criminal Cases by Public Security Organs (the “PRC Criminal
Law”). As of December 31, 2022, we and Deheng had not received any definitive response from the Public Security Bureau.

On behalf of the Company, Deheng went to Sheyang Public
Security Bureau several times to communicate with the police officer in charge of Wei Zhu's case, and Deheng learned that Sheyang Public
Security Bureau suspected that the cryptocurrencies belonged to the Company was related to Wei Zhu's case without any evidence and because
Wei Zhu's case is still in the stage of investigation, they insisted on continuing to implement temporary measures to retain the seized
assets.

According to the legal opinion issued by Deheng Law Firm,
the ownership of the cryptocurrencies seized by Sheyang Public Security Bureau is clear and can be verified as belonging to the Company,
and the seizure of the Company's cryptocurrencies by Sheyang Public Security Bureau is improper. If Sheyang Public Security Bureau does
not release the Company's seized cryptocurrencies, they should issue a written decision in accordance with applicable laws and regulations.

We together with Deheng will continue to vigorously
pursue the Recovery Proceeding, attempting to regain our cold wallet and cryptocurrencies contained therein, which we believe were
wrongfully seized and impounded by the Public Security Bureau. If Wei Zhu 's case enters the judicial procedures, the Company can
submit evidence to the court to plead for restoration of the Company's ownership and control rights over the digital asset hardware
cold wallet and the cryptocurrencies therein, because the evidence that these cryptocurrencies belong to the Company is clear, and
the Company is confident that it can recover these cryptocurrencies through legal procedures. However, it is not certain when Wei
Zhu's case will enter into the judicial process, so until then, these cryptocurrencies will still remain detained by Sheyang Public
Security Bureau, and the Company will remain unable to impose practical control over these cryptocurrencies. Taking into account the
special situation of China's public security and judicial system, the Company has not considered directly filing a lawsuit against
Sheyang Public Security Bureau.

From a legal perspective, the Company is of the view that
it is likely that it will be able to recover control over these cryptocurrencies through judicial procedures, and so management has not
recognized losses of these seized cryptocurrencies. However, if the case is not handled by Sheyang Public Security Bureau or subsequent
judicial proceedings in the manner we anticipate, the Company may also incur related losses, which we are unable to quantify at the moment.

As of December 31, 2022, the Company's net assets were $16,828,864,
of which cash and cash equivalents accounted for 44% and the Bitcoins and USD Coins out-of-control accounted for 23%. In the unlikely
scenario where the Company is unable to recover the out-of-control assets, the Company believes that such loss will not materially affect
the Company's future business development and daily operations.

Other than as described above and elsewhere in this annual
report, we are not aware of any trends, uncertainties, demands, commitments or events that are reasonably likely to have a material adverse
effect on our revenue, income from continuing operations, profitability, liquidity or capital resources, or that would cause our reported
financial information not necessarily to be indicative of future operating results or financial condition.”

Further, the Company proposes to make a reference to the
above disclosure in future 20-F filings under the section “Legal Proceedings”. This will minimize repetition of the same information,
and is also not misleading as the Company itself is not under investigation by the Sheyang Public Security Bureau.

In addition, the Company proposes to include a
summarized version of the above disclosure in the “Report of the Independent Registered Accounting Firm” for future 20-F filings,
and make reference to such disclosure in the relevant notes to the financial statements, being Note 9 (Intangible Assets, Net) and Note
19 (Subsequent Events). This is for the sake of brevity and to increase the readability of the annual report of the Company such that
the same event is not repeated ad verbatim throughout the annual report.

Item 15. Controls and Procedures, page 101

    2.
    We note on page 101 that your management assessed your disclosure controls and procedures (DCP), and your internal controls over financial reporting (ICFR), and concluded that they are effective at December 31, 2022 with no changes in ICFR during 2022. We also note your risk factor disclosures on pages 6, 13 and 14: "Our former officer and director, Wei Zhu, was in control of the Company’s cryptocurrency who had physical control over the Company’s cold wallet. If we do not recover our cold wallet in a timely and cost-efficient manner or at all, the Company may incur a significant loss of the cryptocurrencies. The book value on December 31, 2022 of the Bitcoins and USD Coins stored in the out-of-control wallets was $4,433,817." We further note your risk factor on page 9: "Wei Zhu, your former acting Chief Financial Officer, former Co-Chief Executive Officer, and a former member and Co-Chairperson of the Board, and Minghao Li, a former member of the Board, were suspected of certain criminal offenses." Given that during 2022, certain officers of your company that were in sole control and seemingly physical custody of over almost all your digital assets at December 31, 2022, which represent over 20% of your total assets, were criminally charged and those assets seized, please tell us how you had effective ICFR and DCP if a single person had control over a significant portion of your assets. In your response tell us your consideration of segregation of duties and access to/control of company assets in your ICFR system.

Response: The Company
respectfully submits that at the same time of the Wei Zhu incident, its digital asset hardware cold wallet had been stored in the
safe in the finance room of the Company’s office in Shenzhen, China, and the password and key of the safe were respectively
kept by the former Acting CFO Wei Zhu and our Cashier, while the payment key of the hardware cold wallet was kept by Wei Zhu.
According to the prevailing policy at that time, the use of the Company's cryptocurrencies should first pass the approval process,
following which the former CFO Wei Zhu and the Cashier should jointly open the safe according to the approval record, after which
the former CFO Wei Zhu can operate the hardware cold wallet to use the Company's cryptocurrencies for payment.

However, the incident that caused the Company to lose control
of its cryptocurrency hardware cold wallet was an unusual and unexpected incident, because during the relevant time, Wei Zhu was taken
from the Company's office in Shenzhen, China to cooperate with the investigation unrelated to the Company by Sheyang County Public Security
Bureau in late February 2022, and at that time the Sheyang County Public Security Bureau seized the Company’s safe and forcibly
opened the safe. A few days later, the Company received the destroyed safe, but the cryptocurrency hardware cold wallet stored inside
the safe remained seized by the Sheyang Public Security Bureau, which did not provide any explanation for doing so. At present, because
Wei Zhu’s case has not yet entered the judicial process, and the Company and Deheng Law Office are still in continuous negotiation
with the Sheyang Public Security Bureau. Once Wei Zhu’s case enters the judicial process, the Company is of the view that it is
likely to recover control of the seized cryptocurrency through the judicial process.

We believe that our previous internal controls on assets
management were effective, but the loss of control of physical assets brought about by the above unexpected events also alerts us to possible
deficiencies and room for improvement.

After the Wei Zhu incident, the Company's management team
has also undergone great changes, and the new management team of the Company has further strengthened the management measures of the Company's
assets, which mainly include the following aspects:

· All assets stored in platform accounts, including bank accounts, securities accounts, cryptocurrency
platform accounts, etc., shall have at least two authorized managers, and personnel who undertake independent work functions shall serve
as authorized managers, and the use of any assets shall first pass the Company's financial approval process, then at least two authorized
managers must simultaneously authorize the operation to complete the use or payment of assets.

· The Company's new digital asset hardware cold wallet should have the function of multi-person authorization
management. The use of digital assets must first pass the Company's financial approval process, and then at least two authorized managers
must simultaneously authorize operations to complete the use or payment of digital assets.

· The Company's digital assets will be primarily housed in the U.S. office and jointly managed by authorized
administrators (permanent U.S. residents) of our U.S. subsidiary. For the digital assets seized by the Sheyang Public Security Bureau,
once the seizure is lifted, we will make adjustments in accordance with this standard as soon as possible.

· Considering the huge fluctuations that have occurred in the cryptocurrency market in the past two years, the Company plans to reduce the proportion of digital assets held in the future. In addition, once the Sheyang Public Security Bureau lifts the seizure on our digital assets, the Company will convert some of those digital assets into U.S. dollars in a timely manner to keep a low percentage of the cryptocurrency held by the Company.

Item 16F. Change in Registrant's Certifying Accountant, page 102

    3.
    We note your disclosure on page 103 that you attached the change in auditor letter from your prior auditor, Shanghai Perfect,
    dated April 25, 2023 as Exhibit 15.3, which appears to be filed as Exhibit 15.2. Please amend your filing for the following:

    ·
    Revise the title of the exhibit currently provided as Exhibit 15.2 to be the letter identified as Exhibit 15.3 on page 103 and file
it as that exhibit.

    ·
    Provide the Exhibit 15.2 auditor consent from your prior auditor regarding their report on your December 31, 2021 and 2020 financial
statements included in the filing that are incorporated into your active registration statements on Forms S-8.

    Consider not amending your 2022 Form 20-F until addressing
    all other comments in this letter and those on your registration statement on Form F-1, File No. 333-272274.

Response: The Company respectfully submits that
it will revise the exhibits as instructed upon refiling of the Form 20-F.

Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 104

    4.
    We note that during your fiscal year 2022 you were identified
    by the Commission pursuant to Section 104(i)(2)(A) of the Sarbanes-Oxley Act of 2002 (15 U.S.C. 7214(i)(2)(A)) as having retained, for
    the preparation of the audit report on your financial statements included in the Form 20-F, a registered public accounting firm that has
    a branch or office that is located in a foreign jurisdiction and that the Public Company Accounting Oversight Board had determined it
    is unable to inspect or investigate completely because of a position taken by an authority in the foreign jurisdiction. Please provide
    the documentation required by Item 16I(a) of Form 20-F or tell us why you are not required to do so. Additionally, please amend your Form
    20-F to provide the disclosures required under Item 16I(b) of Form 20-F. Refer to the Staff Statement on the Holding Foreign Companies
    Accountable Act and the Consolidated Appropriations Act, 2023, available on our website at https://www.sec.gov/corpfin/announcement/statement-hfcaa-040623.

Response: Please find below the proposed revised disclosure:

Item 16I(a) of Form 20-F:

Certification by the Chief Executive Officer

Pursuant to Item 16I(a) of Form 20-F

I, Shi Qiu, Director and Chief
Executive Officer of Mercurity Fintech Holding Inc. (the “Company”), certify that to my knowledge following due inquiry:

    (1)
    As of the date hereof, the directors and officers of the Company consist of: Shi Qiu, Lynn Alan Curtis, Daniel Kelly Kennedy, Zheng Cui, Qian Sun, Hui Cheng