SecProbe.io

September 5, 2019
Dai Zheng
Chief Executive Officer
WeTrade Group Inc.
No. 1 Gaobei South Coast
Yi An Men 111 Block 37
Chao Yang District
Beijing City, People's Republic of China
Re:WeTrade Group Inc.
Registration Statement on Form S-1
Filed August 9, 2019
File No. 333-233165
Dear Mr. Zheng:
            We have reviewed your 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.
Form S-1 filed August 9, 2019
Summary
The Offering, page 4
1.Please revise the Offering Proceeds to accurately reflect the number of securities being
offered with the offering price per share.

 FirstName LastNameDai Zheng
 Comapany NameWeTrade Group Inc.
 September 5, 2019 Page 2
 FirstName LastNameDai Zheng
WeTrade Group Inc.
September 5, 2019
Page 2
Risk Factors
If we do not file..., page 17
2.We note your references to filings in 2016.  Please reconcile these disclosures with the
disclosure that the company's inception was March 28, 2019.  We further note similar
timeframe representations in the Security Ownership of Certain Beneficial Owners and
Management table.
Use of Proceeds, page 24
3.Your disclosures regarding the amount of proceeds that are needed to implement your
business development plan do not appear to be consistent.  For example, on page 2 you
indicate that if you raise $150,000 from the offering no funds will be available for
business development.  However, on page 26 you state that raising a minimum of
$100,000 would allow you to implement your business plan whereas on page 48 you refer
to a minimum of $90,000.  Please revise or explain these apparent inconsistencies.
4.Please revise your expenditures to reflect the amount to be raised if 100% and 25% of the
shares being registered are sold.  We note that you allocate $310,000 if 100% of the shares
are sold and $65,000 if 25% of the shares are sold, but the total listed amounts are
$300,000 and $75,000, respectively. Further, please explain why professional fees would
increase from $25,000 if 25% is raised to $150,000 if 100% is raised.
Information with Respect to Registrant, page 32
5.You refer to a common control transaction with UTour PTe. Ltd., which is now a wholly-
owned subsidiary of the company.  Please include a discussion of this transaction here,
including when this transaction took place.  Also, ensure you address the related party
nature of this acquisition, when such entity was established and a description of their
operations in China.  To the extent you intend to conduct significant operations in China,
also revise to include a comprehensive discussion regarding the various risks and
limitations of conducting business in the PRC.
Plan of Operation, page 33
6.You indicate that you are currently developing a business plan that you intend to
implement upon successful completion of registration.  Please revise here to describe with
specificity your plan for the next twelve months.  Provide detail regarding your plan of
operation, including detailed milestones to your business plan, the anticipated time frame
for beginning and completing each milestone, the estimated expenses associated with each
milestone, the expected sources of funding, and how you are to incorporate artificial
intelligence and big data.

 FirstName LastNameDai Zheng
 Comapany NameWeTrade Group Inc.
 September 5, 2019 Page 3
 FirstName LastNameDai Zheng
WeTrade Group Inc.
September 5, 2019
Page 3
Directors and Executive Officers
Background Information about Our Officers and Directors, page 50
7.Please revise the discussions of your management's business experience to provide clear
disclosure regarding the activities of each officer or director during the last five
years.  Refer to Item 401(e) of Regulation S-K for guidance.
Security Ownership of Certain Beneficial Owners and Management , page 55
8.Please identify the natural person(s) who, directly or indirectly, exercise sole or shared
voting and/or investment powers with respect to the shares held by AiShang You Limited.
Signatures, page 57
9.Please revise to have your principal financial officer and principal accounting officer or
controller and the majority of your board of directors sign the registration statement in
their individual capacities.  These signatures should appear in the second signature block
of the signature section.  If someone has signed in more than one capacity, indicate each
capacity in which he or she has signed.  Refer to Instructions for Signatures on Form S-1.
Exhibits
10.Please file exhibits required by Form S-1 (e.g., articles of incorporation, bylaws, legal
opinion, subscription agreement).  See Item 16 of Form S-1.
General
11.Please clarify throughout the filing the number of shares currently issued and outstanding,
the effect on ownership percentages this offering will have, and the dilution effect to take
place upon the sale of shares from this offering.
12.Please remove any references to lines of business that are not part of your business plan.
In this regard, we note multiple references to the rideshare industry and used car sales.
13.Please add a Recent Sales of Unregistered Securities section as required by Item 15 of
Form S-1.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameDai Zheng
 Comapany NameWeTrade Group Inc.
 September 5, 2019 Page 4
 FirstName LastName
Dai Zheng
WeTrade Group Inc.
September 5, 2019
Page 4
            You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have questions regarding comments
on the financial statements and related matters.  Please contact Michael C. Foland, Attorney-
Advisor, at (202) 551-6711 or Barbara Jacobs, Assistant Director, at (202) 551-3735 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services
cc:       Kurt Benedict