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October 20, 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 the responses to the questions
raised by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
in its letter of comments dated September 22, 2023 (the “Comment Letter”) relating to the annual report on Form 20-F
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 below in bold.

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

Item 5. Operating and Financial Review and Prospects

D. Trend Information, page 70

 1. We have reviewed your response to prior comment 1. In your response,
                                            you state that you will, together with D[e]heng, continue to vigorously pursue the Recovery
                                            Proceeding, attempting to regain your cold wallet and the related cryptocurrencies. Please
                                            reconcile this to your statement that if the case enters the judicial procedures, the Company
                                            can submit evidence to the court to plead for restoration of its ownership and control rights
                                            over the cold wallet and cryptocurrencies. In this regard:

 · More
                                            fully articulate your view that the cryptocurrencies were wrongfully seized and that control
                                            over these cryptocurrencies will be recovered by the Company;

 · Clarify
                                            what a Recovery Proceeding is and how it relates to what you refer to as entering “judicial
                                            procedures;”

 · Explain
                                            whether the case entering the judicial procedures is the only mechanism under the law to
                                            recover your cryptocurrencies or if there are other means of recovery;

 · Tell
                                            us whether there are any conditions precedent to entering into the judicial process. If so,
                                            explain whether you believe those conditions represent uncertainties related to the seizure
                                            of your cryptocurrencies; and

 · Update
                                            for us the chronology of events since March 1, 2023.

Response:
The Company submits as follows its proposed supplemental disclosures, in addition to the revised disclosures in its responses
dated August 14, 2023, to be included in future filings.

      1

 1) More fully articulate your view that the cryptocurrencies were wrongfully
                                            seized and that control over these cryptocurrencies will be recovered by the Company.

As disclosed in the Company’s annual report on Form 20-F
for the year 2022, as well as in the Company’s previous response to SEC’s comments, we believe that the cryptocurrencies belonging
to the Company were wrongfully seized by the Sheyang Public Security Bureau. The Company originally obtained the later impounded cryptocurrencies
from selling its equity securities in 2021 and mining operations in 2021 and 2022 and believes that it is the rightful owner of such impounded
digital assets. The Sheyang Public Security Bureau seized our hardware cold wallet and all
cryptocurrencies contained therein without permission or authorization from the Company in February 2022. The Company has
been seeking to restore control of the Company’s cryptocurrencies through various types of administrative procedures, such as actively
communicating with the Sheyang Public Security Bureau together with its PRC legal counsel Deheng Law Firm (“Deheng”) since
the incident.

At present, we think the Company has provided sufficient
evidence to prove the Company’s ownership of the cryptocurrencies taken by the Sheyang Public Security Bureau, which the Company
believes has reached the standard of high probability. The Sheyang Public Security Bureau has admitted that the seizure measure was made
on a temporary basis and the Sheyang Public Security Bureau's handling of the cases of Wei Zhu or Wei Zhu’s wife Jianming Jing
(“Jing”) does not conclusively determine the ownership of the Company's cryptocurrencies.

In the past year and a half, the Sheyang County
Public Security Bureau repeatedly avoided, and did not respond to our complaint in accordance with the procedural provisions despite
our continuous efforts to resolve the cryptocurrency matter. As such, the Company has submitted the “Application for State Compensation”
to the Public Security Bureau of Sheyang County, and has also submitted the “Information and Supervision Application” to
Yancheng City Public Security Bureau, the authority supervising Sheyang County Public Security Bureau, reporting the Public Security
Bureau of Sheyang County’s noncompliance with applicable rules and procedures. Further, the Company will, depending on the
situation, decide whether to submit relevant materials to the Sheyang County Discipline Inspection Commission and Yancheng City Discipline
Inspection Commission to further pursue this matter.

 2) Clarify what a Recovery Proceeding is and how it relates to what you
                                            refer to as entering “judicial procedures.

The "Recovery Proceeding” refers to all
of the Company’s efforts to regain the ownership and custody of the cryptocurrencies in accordance with the relevant procedures
of the Public Security Bureau, procuratorate, court of competent jurisdiction and other authorities in China, which includes formal and
informal, written and verbal communication with the Public Security Bureau at all levels, including the county, city and potentially
higher levels, judicial procedures with the Chinese courts, administrative appeals against the Sheyang County Public Security Bureau
and administrative application for the State compensation. Therefore, the judicial procedures are part of our Recovery Proceeding.

If and when the Sheyang County Public Security Bureau
classifies the detained cryptocurrencies as potential criminal proceeds and transfers the same to the procuratorate, which later files
with the Sheyang County court a lawsuit claiming the nature the seized property, the Company may then appeal to the Sheyang County Court
reclaiming the cryptocurrencies. If and when the above occurs, we will enter into judicial procedures to recover our seized cryptocurrencies.

In addition, it is theoretically possible that the
Company can also directly sue the Sheyang Public Security Bureau for improper seizure of assets to start another judicial proceeding.
However, the Company has deliberately not chosen such an approach, considering the specific situation of China's public security and
judicial system.

 3) Explain whether the case entering the judicial procedures is the only
                                            mechanism under the law to recover your cryptocurrencies or if there are other means of recovery.

Entering the judicial procedures is not the only
mechanism provided for by law to restore our cryptocurrencies. On a track parallel with the judicial procedures in Sheyang Court, the
Company and Deheng have also been actively pursuing the following two avenues to recover the wrongfully seized cryptocurrencies:

 a) Applying for state compensation. This is an administrative
                                            procedure. On October 12, 2023, the Company applied to Sheyang County Public Security
                                            Bureau for compensation for the wrongfully seized digital assets, in compliance with the
                                            provisions of Articles 18, 21 and 40 of the State Compensation Law, provisions of Article 6
                                            of the Provisions on Procedures for Handling State Compensation Cases by Public Security
                                            Organs, and provisions of Article 3 of the Interpretation of the Supreme People's Court
                                            and the Supreme People's Procuratorate on Several Issues Concerning the Application of Law
                                            in Handling Criminal Compensation Cases.

      2

 b) Filing a complaint with the Public Security Bureau of Yancheng
                                            City. This is also an administrative procedure. On October 12, 2023, the Company filed
                                            a complaint to the Public Security Bureau of Yancheng City, which is the superior authority
                                            to Sheyang County Public Security Bureau, in accordance with the provisions of Article 197
                                            of the Provisions on the Procedure of Handling Criminal Cases by Public Security Organs (2020
                                            Amendment), alleging and citing certain violations of rules by the Public Security Bureau
                                            of Sheyang County and urging the Public Security Bureau of Yancheng City to request the Public
                                            Security Bureau of Sheyang County make a decision on the digital currencies wrongfully seized.

 4) Tell us whether there are any conditions precedent to entering into
                                            the judicial process. If so, explain whether you believe those conditions represent uncertainties
                                            related to the seizure of your cryptocurrencies.

Under the mainland Chinese judicial system, the
prerequisites for entering into the criminal judicial process include: a) the Public Security Bureau of proper jurisdiction having completed
its investigation and collection of evidence and having decided to send the case to the procuratorate, and b) the procuratorate having
made a decision to prosecute the case based on the evidence obtained.

As stated in detail below in bulletin 5 to this
comment, we have discovered and confirmed with the Sheyang County Court that a) Wei Zhu's case has entered into judicial procedures as
of the date of this letter; and b) our wrongfully seized digital assets were classified by the Sheyang County Public Security Bureau
under a separate seizure list associated with Jianming Jing (“Jing”), Wei Zhu's wife, and therefore did not enter into the
adjudication with Wei Zhu as of the date hereof.

As of the date hereof, we are facing uncertainties
as to whether the Sheyang County Public Security Bureau will refer Jing’s case together with the cryptocurrencies to the procuratorate
and whether the prosecutor will determine to prosecute Jing. In addition, the Sheyang County Public Security Bureau explained to Deheng
that the Bureau is looking to detain other persons whom the Bureau believes are connected with Wei Zhu’s case and hence the Bureau
is not in a position to determine whether the seizure measures of the Company's cryptocurrencies should be lifted until it detains the
principal suspect with whom Wei Zhu and Jing were suspected of being affiliated with.

 5) A chronology of Wei Zhu incident since March 1, 2023

Since March 1, 2023, Deheng has communicated
with the Sheyang Public Security Bureau and the Sheyang court multiple times on behalf of the Company, and has provided evidence and
raised relevant demands for the restoration of the control of the Company's cryptocurrencies, as follows:

 · From
                                            April 6, 2023 to May 3, 2023, Deheng continued to try to contact the police officer
                                            of Sheyang Public Security Bureau responsible for Wei Zhu's case by phone and left multiple
                                            voice messages to the police officer, but was unable to reach the relevant personnel.

 · On
                                            June 28, 2023, Deheng went to the Sheyang Public Security Bureau to seek on-site communication
                                            with the police officer in charge of Wei Zhu's case but was unable to meet the police officer.

      3

 · On
                                            July 4, 2023, Deheng went to the Sheyang Public Security Bureau and reported through
                                            the on-site public reception window of the Sheyang Public Security Bureau that the police
                                            officers responsible for Wei Zhu's case did not follow the procedures of the public security
                                            system and did not provide written responses to the Company's appeals beyond the statutory
                                            deadline.

 · On
                                            July 5, 2023, Deheng went to the Sheyang Public Security Bureau and reported to the
                                            office of the Sheyang Public Security Bureau that the police officers responsible for Wei
                                            Zhu's case did not comply with procedural regulations and did not provide a written response
                                            to the Company's appeal beyond the statutory deadline.

 · On
                                            August 31, 2023, Deheng had a telephone conversation with the procurator of Sheyang
                                            County Procuratorate responsible for Wei Zhu's case, and the prosecutor informed that the
                                            case of Wei Zhu had been transferred to the Sheyang County court for adjudication, and that
                                            the digital assets seized were not under Wei Zhu's name and are still temporarily detained
                                            by the Sheyang County Public Security Bureau. On the same day, Deheng contacted the judge
                                            of the Sheyang County court in charge of Wei Zhu's case, and the judge communicated to Deheng
                                            that the materials submitted by the Sheyang County Public Security Bureau and the Sheyang
                                            County Procuratorate regarding Wei Zhu's case did not mention the seizure of the digital
                                            assets.

 · On
                                            September 1, 2023, Deheng went to the Sheyang Public Security Bureau, and the office
                                            of the Sheyang Public Security Bureau stated that they would provide feedback to the head
                                            of the Economic Investigation Brigade of the Sheyang Public Security Bureau (the person in
                                            charge of the Wei Zhu case at the Sheyang Public Security Bureau).

 · On
                                            September 4, 2023, Deheng sent written explanatory materials to the Sheyang Court and
                                            the Sheyang Procuratorate, reflecting on the situation wh