SecProbe.io

September 3 , 201 9
Via E-mail
Kirt Gardner
Chief Financial Officer
UBS Group AG
Bahnhofstrasse 45, CH -8001
Zurich
Switzerland

 Re: UBS Group AG
  UBS AG
  Form s 20-F for the Fiscal Year Ended December 31, 201 8
  Filed March 15 , 2019
  File No s. 1-36764 and 1 -15060

Dear Mr. Gardner :

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and  we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments , we ask you to provide us with information so we may better
understand y our disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell  us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. Please describe to us the nature and extent of any past, current, and anticipated contacts
with Syria and Sudan since our 2016 review , including contacts with those countries’
governments, whether through subsidiaries, affiliates, or other direct or indirect
arrangements.  As you are aware, Syria and Sudan are designated by the U.S. Department
of State as state sponsors of terrorism and  are subject to U.S. economic sanctions and/or
export controls.  Your Form 20 -F does not provide disclosure about those countries.

2. Please discuss the materiality of any contacts with Syria and Sudan in quantitative terms
and in terms of qualitative fact ors that a reasonable investor would deem important in
making an investment decision.  Tell us the approximate dollar amounts of any revenues,
assets and liabilities associated with those countries for the last three fiscal years and the

Kirt Gardner
UBS Group AG
 September 3 , 2019
 Page 2

 subsequent interim period.  Address for us the potential impact of the investor sentiment
evidenced by divestment and similar initiatives that have been directed toward companies
that have operations associated with state sponsors of terrorism.

We urge  all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or m e at (202) 551 -
3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Todd Tuckner , Controller
  UBS Group AG

  Pamela Long
  Assistant Director