SecProbe.io

CORRESP
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filename1.htm

December
26, 2023

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

Division
of Corporations Finance Office of Technology

100
F Street, N.E.

Washington,
D.C. 20549

Re:
SEATech Ventures Corp.

Form
10-K for Fiscal Year Ended December 31, 2022

Filed
on March 30, 2023

File
No. 333-230479

To
the men and women of the SEC:

On
behalf of SEATech Ventures Corp. (“SEATech”,”our”, “we”, “us”, or the “Company”),
are responding to comments contained in the Staff letter, dated December 14, 2023 addressed to Mr Tan Hock Chye, the Company’s
Chief Financial Officer, with respect to the Company’s filing of its Form 10-K for Fiscal Year Ended December 31, 2022, on March
31, 2023.

The
Company has replied below on a comment-by-comment basis, with each response following a repetition of the Staff’s comment to which
it applies.

SEC
Comment(s) /Analysis

Form
10-K Filed March 31, 2023

Form
10-K for Fiscal Year Ended December 31, 2022

Item
9A, Controls and Procedures

Disclosures
Control and Procedures, page 19

 1. Please
                                            address the following:

 a. We
                                            note you provided the management’s assessment on your internal control over financial
                                            reporting. However, the management’s conclusion as to the effectiveness of your disclosure
                                            controls and procedures was omitted from the filing. Please amend to include the missing
                                            disclosure. Refer to Item 307 of Regulation S-K.

 b. Revise
                                            to identify the specific COSO framework used for your assessment of the effectiveness of
                                            the internal control over financial reporting, i.e., the 1992 Framework or the updated 2013
                                            Framework

Company
Response:

Our
response to the above comments as below:

 a. The
                                            management’s conclusion is on Page. 20 instead of Page 19, and reproduced as below:-

“Based
on such evaluation, the Company’s management concluded that, during the period covered by this Report, internal controls and procedure
over were not effective. This was due to deficiencies that existed in the design or operation of our internal controls over financial
reporting that adversely affected our internal controls and that may be considered to be material weaknesses.”

 b. The
                                            company’s assessment of the effectiveness of the Internal control over Financial Reporting
                                            is based on COSO Internal Control – Integrated Framework (ICIF-2013). Our response
                                            has been added to the corresponding page 20 & 21.

Consolidated
Statements of Operations and Comprehensive Loss, page F-4

 2. Please
                                            revise to present basic and diluted net loss per share amounts rounded to the nearest cent
                                            (i.e., only two decimal points), in order not to imply a greater degree of precision than
                                            exists.

Company
Response:

Our
response to the above comment has been added to the page F-4

*We
are not requesting acceleration but do acknowledge the following:

-Should
the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission
from taking any action with respect to the filing;

-The
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the
company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

-The
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

    Date:
    December 26, 2023

    /s/
    Tan Hock Chye

    Tan
    Hock Chye

    Chief
    Financial Officer