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March 10, 2022
Andrew Cross
Chief Financial Officer
Asian Infrastructure Investment Bank
AIIB Headquarters, Tower A
Asia Financial Center
No. 1 Tianchen East Road
Chaoyang District, Beijing 100101
People’s Republic of China
Re:Asian Infrastructure Investment Bank
Amendment No. 1 to Registration Statement under Schedule B
Filed February 18, 2022
File No. 333-261099
Dear Mr. Cross:
            We have reviewed your amended registration statement and have the following
comments.  In some of our comments, we may ask you to provide us with information so we
may better understand your disclosure.
            Please respond to this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our December 15, 2021 letter.
Amendment No. 1 to Schedule B filed February 18, 2022
Amendment No. 5 to Form 18-K filed February 18, 2022 - Exhibit 14
Loans by Sector, page 1
1.In response to comment 3, your revised disclosure provides that, "The following table sets
forth AIIB’s loan portfolio by sector, as classified by AIIB in accordance with the
methodology described above: ..." However, a table was not included; please revise to
include the table.

 FirstName LastNameAndrew Cross
 Comapany NameAsian Infrastructure Investment Bank
 March 10, 2022 Page 2
 FirstName LastNameAndrew Cross
Asian Infrastructure Investment Bank
March 10, 2022
Page 2
Form 18-K for Fiscal Year Ended December 31, 2021 - Exhibit 3
Financial Instruments, page 21
2.Please discuss whether your loan agreements contain confidentiality clauses.  Also
describe in general the collateral agreements and security interests entered into with the
loans and discuss whether the terms of your loan agreements include any acceleration
clauses upon which AIIB could terminate the agreement and demand immediate full
repayment from the borrower upon default.

General
3.We note your response to comment 5 and your revised disclosure on page 8 of the
prospectus that provides:

"The PCAOB’s inability to conduct inspections in mainland China and Hong Kong, China
prevents the PCAOB from fully evaluating audits and quality control procedures of the
Bank’s external auditor and the mainland Chinese affiliate of the Bank’s external auditor.
As a result, investors in the Bank’s securities are deprived of the benefits of such PCAOB
inspections. The inability of the PCAOB to conduct inspections of external auditors in
mainland China and Hong Kong, China makes it more difficult to evaluate the
effectiveness of the audit procedures or quality control procedures of the Bank’s external
auditor as compared to auditors outside of mainland China and Hong Kong, China that are
subject to PCAOB inspections, which could cause investors and potential investors in the
Bank’s securities to lose confidence in the Bank’s audit procedures and financial
information and the quality of its financial statements."

We reissue in part our prior comment. On the cover page of the prospectus, please
disclose whether your auditor is subject to the determinations announced by the PCAOB
on December 16, 2021 and highlight the risks discussed on page 8.  Please also include a
cross-reference to the more detailed disclosure in the registration statement.
4.We note recent news articles discussing a possible executive order by the President of the
United States that would prohibit American investments in Chinese technology firms and
startups. Please advise us how this executive order could have an effect, if any, upon
AIIB's business and/or U.S. investments in AIIB's securities. To the extent material,
please consider whether such disclosure should be included in the prospectus.
5.We note that Russia is a member of AIIB and that representatives of Russia serve on your
board of directors and as senior management. In addition, as of December 31, 2020, you
had approved financing for projects in Russia.  Please describe the impact of Russia’s
invasion of Ukraine on AIIB’s business, projects and operations, including whether and
how sanctions imposed upon Russia, related individuals or entities, may impact AIIB.
Also explain in greater detail the bank’s financing to Russia and the related projects.

 FirstName LastNameAndrew Cross
 Comapany NameAsian Infrastructure Investment Bank
 March 10, 2022 Page 3
 FirstName LastName
Andrew Cross
Asian Infrastructure Investment Bank
March 10, 2022
Page 3

            Please contact Tom Kluck at 202-551-3233 or Michael Coco at 202-551-3253 if you
have any questions.
Sincerely,
Division of Corporation Finance
Office of International Corporate
Finance
cc:       Krystian Czerniecki