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January 3, 2020

VIA EDGAR

Marianne Dobelbower and Jacob Sandoval

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    KraneShares Trust: KFA Global Carbon ETF

    (File Nos. 333-180870 and 811-22698)

Dear Ms. Dobelbower and Mr. Sandoval:

On June 16, 2019, KraneShares
Trust (“Registrant”) filed Post-Effective Amendment No. 194 to its Registration Statement on Form N-1A (“Post-Effective
Amendment No. 194”) with the U.S. Securities and Exchange Commission (“SEC”) pursuant to Rule 485(a)(2) under
the Securities Act of 1933, as amended (Accession Number 0001615774-19-009301). Post-Effective Amendment No. 194 was filed to register
a new series of the Registrant, the KFA Global Carbon ETF (“Fund”).

On September 16, 2019,
members of the SEC staff (“Staff”) provided additional comments regarding Post-Effective Amendment No. 194. Those additional
comments and the Registrant’s responses thereto are set forth below. Defined terms used below have the same meaning as in
Post-Effective Amendment No. 194, unless otherwise indicated.

 1. Please supplementally explain how the Fund will comply with the asset segregation requirements
of Investment Company Act Release No. 10666 and describe any material differences between futures on carbon offset credits and
other types of futures, such as with respect to operational and margin requirements.

RESPONSE: The Registrant
does not expect the Fund’s investments in futures on carbon offset credits to raise any concerns under Investment Company
Act Release No. 10666 and related SEC guidance and interpretations. In particular, the Fund expects to, directly or indirectly
through the Subsidiary, invest approximately 10% of its net assets in futures on carbon offset credits and will only seek to maintain
notional exposure to carbon offset credits equal to 100% of the Fund’s net assets (e.g., the Fund does not intend
to seek leveraged exposure to carbon offset credits). Although futures on carbon offset credits call for physical settlement, any
futures commission merchant (“FCM”) agreement for the Fund will require cash settlement and prohibit physical delivery
to the Fund. In addition, Krane intends to “roll” the futures prior to their expiration dates into futures with later
expiration dates. As a result, Krane does not anticipate that the Fund will take physical delivery of carbon offset credits at
any time. Accordingly, the Fund, directly and/or indirectly through the Subsidiary, will establish a segregated account containing
cash and other liquid assets equal to the net amount owed by the Fund under the futures contracts, if any, as determined (or “marked
to market”) daily, less any margin. Such segregated amounts will result in compliance by the Fund with Investment Company
Act Release No. 10666, the Dreyfus Strategic Investing and Dreyfus Strategic Income no-action letter, the Merrill Lynch
Asset Management, L.P. no-action letter and/or other applicable SEC and/or staff guidance.

K&L Gates LLP

1601 K Street NW Washington DC 20006

T +1 202 778 9000 F +1 202 778 9100 klgates.com

Securities and Exchange Commission

January 3, 2020

Page 2

 2. A.        Supplementally describe the average trading volume of futures on carbon offset
                                                           credits issued under the California Carbon Allowance (“CCA”) and Regional Greenhouse Gas Initiative
                                                           (“RGGI”) regimes. Discuss what percentage of the average trading volume the Fund might expect to trade on any
                                                           given day and the anticipated impact thereof on the carbon offset credits market, the Fund and its capacity.

RESPONSE: As of August 31,
2019, the average monthly trading volumes of futures on carbon offset credits issued under the CCA and RGGI regimes were $414 million
and $37 million, respectively. The average monthly trading volumes of these futures grew by approximately 120% and 77.9%, respectively,
during the past year, evidencing a robust and fast-growing market. Below are charts showing the CCA and RGGI average trading volumes
from October 2018 to September 2019:

Securities and Exchange Commission

January 3, 2020

Page 3

Based on Krane’s expectations
regarding the potential size of the Fund within its first year of operations and, critically, assuming no growth in the size of
the market for futures on carbon offset credits, which, as discussed below, Krane believes is highly unlikely, Krane expects that
the Fund’s trades are unlikely to exceed 25% of the average monthly trading volume for either CCA or RGGI.1 Accordingly,
Krane does not expect the Fund’s trades to have a material impact on the carbon offset credits market, the Fund or its capacity.

B.       Supplementally provide a capacity
analysis for the Fund, which may include qualitative data as appropriate and information regarding the trading experience of other
vehicles providing exposure to futures on carbon offset credits.

1
At present, Krane expects that the Fund’s net assets may grow up to $100 million in the Fund’s first year of operations.
Futures on carbon offset credits issued under the RGGI regime currently have less trading volume than the other futures in which
the Fund intends to invest and the Fund’s trades may potentially have a greater impact on the market for those futures.
To prevent any concerns regarding the impact of the Fund’s trades on that market, the Fund, as proposed, will track an index
in which these futures contracts are limited to 10% of the weight of the index as of each Index reconstitution date. Accordingly,
the Fund’s total investments in such futures contracts will be limited 10% of the Fund’s net assets on a notional
basis as of each Index reconstitution date and will vary during the year based only on market movements. Assuming Fund net assets
of $100 million, investments of approximately 10% or $10 million of the Fund’s net assets in these futures, and an annual
portfolio turnover rate of 100%, the Fund’s trades would have constituted only 2.73% of the average monthly trading volume
of such futures during the past year.

Securities and Exchange Commission

January 3, 2020

Page 4

RESPONSE: Krane expects that
the Fund could grow indefinitely without affecting the Fund’s capacity, which would be determined by the liquidity of its
investments. As the SEC staff is aware, there is no ETF-specific liquidity requirement that would limit the Fund’s investments
in futures on carbon offset credits. Indeed, NYSE Arca Rule 8.600-E, Commentary .01(d) (“generic listing standards”),
which has been approved by the SEC, does not impose any liquidity requirements with respect to the exchange-traded derivatives
in which an exchange-traded fund (“ETF”) may invest. Rather, this listing standard requires that the SEC be able to
obtain trading information about at least 90% of an ETF’s exchange-traded derivatives through the Intermarket Surveillance
Group or pursuant to a comprehensive surveillance sharing agreement with such derivatives’ principal exchange.

As a registered open-end fund, however,
the Fund is subject to Rule 22e-4, which provides the key liquidity restriction applicable to its investments in futures on carbon
offset credits. Under Rule 22e-4, no open-end registered fund may acquire an “illiquid investment” if, immediately
after its acquisition, the fund would have invested more than 15% of its net assets in illiquid investments. Rule 22e-4 defines
illiquid investments to mean, in essence, investments that cannot be sold under current market conditions within seven calendar
days without significantly affecting their market value.

Krane
does not currently expect that any of the futures contracts purchased by the Fund will qualify as illiquid investments. Krane
notes that the market for futures on carbon offset credits has continued to grow in recent years and the market for them has significantly
matured in a short period of time. As noted above, the average monthly trading volumes of carbon offset credits issued under the
CCA and RGGI regimes grew by approximately 120% and 77.9%, respectively, during the past year.2 Krane expects that
trading volumes of these futures will continue to grow and that the Fund could contribute to this growth. Krane believes these
are important factors to consider in analyzing the liquidity of the Fund’s investments in these instruments as the markets
for carbon offset credits and futures on carbon offset credits grow.

However, even if 100% of the Fund’s
investments in futures on carbon offset credits were deemed to be “illiquid investments,” the Fund would still be in
compliance with Rule 22e-4. This is the case because approximately 90% of the Fund’s net assets (directly or indirectly through
the Subsidiary) are expected to be invested in highly liquid fixed income instruments, such as U.S. government securities and/or
cash equivalents. Stated differently, Krane does not expect the Fund ever to invest more than 10% of its net assets (directly or
indirectly through the Subsidiary) in futures on carbon offset credits. Accordingly, even if all such futures were deemed to be
illiquid within the meaning of Rule 22e-4, no more than 10% of the Fund’s net assets would be invested in illiquid investments.
As a result, the Fund would easily comply with Rule 22e-4.

In support of its belief that futures
on carbon offset credits are sufficiently liquid to support the arbitrage mechanism of the Fund, Krane notes that the SEC has previously
approved, pursuant to Rule 19b-4 under the Securities Exchange Act of 1934, a listing standard for an exchange-traded commodity
trust that invested solely in futures on EUAs. In that case, the Commission’s approval was based, in part, on an analysis
of the market depth and liquidity of the markets for the futures.3

2
This growth has also occurred in futures of carbon offset credits issued under the European Union Allowance, which grew by 105%
during the same time period.

3
Securities Exchange Act Release No. 57838, (May 20, 2008), 73 FR 30649 (May 28, 2008) (SR-NYSEArca-2008-09) (Order Granting Approval
of Proposed Rule Change, as Modified by Amendment Nos. 1 and 2 Thereto, Relating to the Listing and Trading of Shares of the AirShares
EU Carbon Allowances Fund). This fund eventually ceased operations following a lack of investor interest, rather than by reason
of any capacity constraints.

Securities and Exchange Commission

January 3, 2020

Page 5

Further, Krane notes that there
currently exists at least one exchange-traded product, WisdomTree Carbon (“CARB”), that invests solely in futures on
carbon offset credits. CARB, which is listed on the London Stock Exchange, has been operational for over 11 years, and Registrant
is not aware of any indication its operations have that these products have suffered from a capacity constraint or that the market
for futures on carbon offset credits has been affected by their trading.

Although
the Registrant does not expect it to be relevant based on the analysis set forth above, the Registrant acknowledges the SEC staff’s
position that ETFs may not suspend creation orders for their shares. The Registrant and Krane will take such steps as necessary
to prevent the Fund from needing to suspend creation orders in the unexpected event that the Fund should ever face limited capacity
for any reason. Such steps could include, for example, changing the Fund’s investment objective to relate to a more diversified
index and/or broadening the assets in which the Fund may invest (e.g., to include swaps) to obtain exposure to the relevant
carbon credit offsets.4

C.       Supplementally state whether
the futures contracts in which the Fund (through the Subsidiary) will invest can be transacted in kind in connection with creation
and redemption orders for Fund shares.

RESPONSE: The futures contracts
in which the Fund (through the Subsidiary) will invest are not currently able to be transacted in kind.

*        *        *        *        *

If you have any additional questions regarding
the enclosed information, please contact me at (202) 778-9475 or Franklin Na at (202) 778-9473.

    Regards,

    /s/ Stacy L. Fuller

    Stacy L. Fuller

    cc:
    Jonathan Krane

    Odette Gafner

    Jonathan Shelon

    Krane Funds Advisors, LLC

    Franklin Na

    K&L Gates LLP

4 The Registrant would notify investors
of such a change and comply with the requirements of Rule 485(a) under the Securities Act of 1933 to amend its registration statement
on Form N-1A.