SecProbe.io

United States securities and exchange commission logo
June 25, 2024
Anthony Santelli
Chief Financial Officer
Blue Biofuels, Inc.
3710 Buckeye Street, Suite 120
Palm Beach Gardens, FL 33410
Re:Blue Biofuels, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 000-54942
Dear Anthony Santelli:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 14
1.We reference the disclosure that you determined that your disclosure controls and
procedures were "sufficient" as of December 31, 2023.  Please revise Item 9A in an
amended Form 10-K to clearly state management's conclusion on whether your disclosure
controls and procedures were "effective" at the end of the period. Refer to the guidance in
Item 307 of Regulation S-K. You may provide an abbreviated amendment that includes a
cover page, explanatory note, the complete text of Item 9A, a signature page and the
certification required by Item 601(b)(31) of Regulation S-K, including paragraphs 1,2,4
and 5. Please ensure the revised certifications refer to the appropriate amendment and are
currently dated.

 FirstName LastNameAnthony Santelli
 Comapany NameBlue Biofuels, Inc.
 June 25, 2024 Page 2
 FirstName LastName
Anthony Santelli
Blue Biofuels, Inc.
June 25, 2024
Page 2
Report of Independent Registered Public Accounting Firm, page F-2
2.On May 3, 2024, the Commission entered into an order instituting settled administrative
and cease-and-desist proceedings against BF Borgers CPA PC and its sole audit partner
Benjamin F. Borgers CPA (individually and together BF Borgers).  Please refer to the
order on the SEC’s website at https://www.sec.gov/files/litigation/admin/2024/33-
11283.pdf and the related staff statement at
https://www.sec.gov/corpfin/announcement/staffstatement-borgers-05032024.  Because
BF Borgers has been denied the privilege of appearing or practicing before the
Commission, issuers that have engaged BF Borgers to audit or review financial
information to be included in any Exchange Act filings to be made on or after the date of
the Order will need to engage a new qualified, independent, PCAOB-registered public
accountant.
General
3.We note you do not include Item 1.C Cybersecurity. Please revise or advise us why you
do not provide disclosure as applicable under Item 106 of Regulation S-K.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at 202-551-4391 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services