SecProbe.io

CORRESP
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filename1.htm

March
25, 2024

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

Division
of Corporations Finance

100
F Street, N.E.

Washington,
D.C. 20549

Re:
SEATech Ventures Corp.

Form
8-K

Filed
November 2, 2023

File
No. 333-230479

To
the men and women of the SEC:

On
behalf of SEATech Ventures Corp. (“SEATech”, “SEAV”, “our”, “we”, “us”, or
the “Company”), are responding to comments contained in the Staff letter, dated January 2, 2024 addressed to Mr Tan Hock
Chye, the former 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, and Form 8-K filed November 2, 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
8-K Filed November 2, 2023

Item
2.01 Completion of Acquisition or Disposition of Assets, page 2

We
note from your disclosure in this Form 8-K that on October 13, 2023, you completed the acquisition of Just Supply Chain Limited for 21,831,660
units in stock valued at $17.5 million. Please tell us in your response how you recorded this transaction and your consideration to provide
financial statements of the acquiree. Your response should include your assessment of significance in accordance with Rule 1-02(w) of
Regulation S-X in assessing compliance with Rule 3-05(a)(2)(ii) of Regulation S-X if you have determined that a business has been acquired.

Company
Response:

We,
SEATech Ventures Corp. hereby writing to inform Securities and Exchange Commission of a significant development regarding the acquisition
deal with Just Supply Chain Limited.

Following
a thorough due diligence conducted by the management team, it has come to our attention that there are discrepancies between
the information provided by Just Supply Chain Limited’s management and the findings of our team. These inconsistencies raise
concerns about the accuracy and integrity of the information presented to us during the negotiation process

After
careful consideration and deliberation, our management has made the decision not to proceed ahead with the deal at this time. It is essential
for us to prioritize transparency, accountability, and trustworthiness in all of our business dealings. Regrettably, the current circumstances
do not align with these principles.

Furthermore,
we would like to assure you that SEATech management is committed to ensuring that any share issuances related to this matter will be
reversed in a proper and appropriate manner. We will take the necessary steps to rectify any potential discrepancies and uphold the integrity
of our processes.

Thank
you for your attention to this important issue.

*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: March 25,
  2024

  /s/ Chin
  Chee Seong

  Chin Chee Seong

  Chief Executive
  Officer