SecProbe.io

CORRESP
1
filename1.htm

February
13, 2023

Securities
and Exchange Commission

Office
of Trade & Services

Division
of Corporation Finance

100
F Street NE

Washington,
D.C. 20549-3561

Re: INFINT
                                            Acquisition Corporation

                                            Amendment No. 1 to Registration Statement on Form S-4

                                            Filed on December 1, 2022

                                            File No: 333-267662

Dear
Mr. Anderegg:

On
behalf of INFINT Acquisition Corporation (the “Company”), set forth below are the Company’s responses to the
comments of the Staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission
(the “Commission”) relating to the Company’s Amendment No. 1 to Registration Statement on Form S-4 (File No.
333-267662) (“Amendment No. 1”). An electronic version of Amendment No. 2 (“Amendment No. 2”)
to the Registration Statement has been concurrently filed with the Commission through its EDGAR system. The Registration Statement, as
amended by Amendment No. 2, is referred to as the “Amended Registration Statement.”

Set
forth below are the responses of the Company to the comments of the Staff’s letter to the Company, dated February 6, 2023, relating
to Amendment No. 1. For ease of reference, the text of the comments in the Staff’s letter is reproduced in italics herein.
Unless otherwise indicated, all references to page numbers in such responses are to page numbers in the Amended Registration Statement.
Capitalized terms used in this letter but not otherwise defined herein have the respective meanings ascribed to them in the Amended Registration
Statement.

Amendment
No. 1 to Form S-4 filed December 1, 2022

Cover
Page

1. We
                                            note your revisions in response to comment 1. Please revise the cover page to disclose the
                                            conversion ratio based on the number of Seamless ordinary shares issued and outstanding as
                                            of the most recent practicable date. Please include this disclosure elsewhere as appropriate.

Response:
In response to the Staff’s comment, the Company has revised the cover page and the disclosures on pages 9, 21, 96 and 167
of the Amended Registration Statement to disclose the conversion ratio based on the number of Seamless ordinary shares issued and
outstanding as of February 8, 2023.

Greenberg
Traurig, LLP

One
Vanderbilt Avenue | New York, NY 10027 | T +1 212.801.9200 | F +1 212.801.6400

www.gtlaw.com

Securities
and Exchange Commission

Office
of Trade and Services

Division
of Corporation Finance

February
13, 2023

Page
2

Summary
- Seamless Group Inc., page 20

2. We
                                            note your revisions in response to comment 7. While you include the unaudited pro forma condensed
                                            statement of operations, this does not illustrate the impact of the divestitures as you do
                                            not discuss the financial position of the company before the divestitures. Please revise
                                            to provide a discussion that illustrates how the divestitures will impact the business and
                                            financial results on an ongoing basis.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 21 of the Amended
Registration Statement to illustrate the summary financial performance of Seamless prior to the Divestitures and illustrate the impact
of the Divestitures thereon, and to direct investors to more detailed discussions of the impact of the Divestitures on the business and
financial results of Seamless elsewhere in the Amended Registration Statement.

3. Here
                                            and elsewhere that you disclose that Tranglo services transactions between more than 20 countries
                                            in Southeast Asia, please provide context so that it is clear whether the majority of such
                                            transactions occur in a few countries or are more evenly spread across 20 countries. To the
                                            extent that the majority of transactions are in a few countries, please disclose those countries.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on pages 21, 173 and 201 of the Amended
Registration Statement to clarify that a majority of Tranglo’s remittance revenue is derived from transactions for customers in
Hong Kong, Singapore and the Republic of South Korea.

Risk
Factors, page 47

4. To
                                            the extent material, discuss any reputational harm you may face in light of the recent disruption
                                            in the crypto asset markets. For example, discuss how market conditions have affected how
                                            your business is perceived by customers, counterparties, and regulators, and whether there
                                            is a material impact on your operations or financial condition.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 54 of the Amended Registration Statement
to disclose how recent volatility, security breaches, manipulative practices, business failure and fraud in the cryptocurrency industry
may adversely impact Tranglo and Seamless, including their reputation with their customers, partners and other business stakeholders.

5. To
                                            the extent material, describe any actual or potential material impact to your financial condition
                                            and results of operations, or material decreases in demand for your on-demand remittance
                                            services, due to recent disruptions in the crypto asset markets and the bankruptcy of FTX,
                                            as well as the significant volatility in the price of XRP. To the extent possible, please
                                            revise to quantify the impact of any decreased demand due to the volatility of XRP, and otherwise
                                            disclose any actual or potential material impacts to your business or financial condition.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 54 of the Amended Registration Statement
to disclose how recent volatility, security breaches, manipulative practices, business failure and fraud in the cryptocurrency industry
may adversely impact Tranglo. The Company respectfully advises the Staff that Seamless has not to date observed any material impacts
on its financial condition or results of operations or material decrease in demand for its ODL service, and accordingly is unable to
quantify any impact of decreased demand due to volatility of XRP.

Greenberg
Traurig, LLP

www.gtlaw.com

Securities
and Exchange Commission

Office
of Trade and Services

Division
of Corporation Finance

February
13, 2023

Page
3

The
funding process used by Tranglo..., page 54

6. In
                                            response to comment 11 you disclose that you have obtained relevant approval for your existing
                                            operations that involve cryptocurrency. However, we note your response to comment 45 where
                                            you state that Seamless’ business is structured so as to not require Seamless to comply
                                            with the currently applicable cryptocurrency regulations in the jurisdictions in which it
                                            operates. Please reconcile these statements, and explain how your business is structured
                                            such that you do not have to comply with applicable cryptocurrency regulations.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 54 of the Amended Registration Statement
to reconcile these statements.

7. Your
                                            response to comment 11 states that you are not aware of pending regulatory changes that would
                                            prevent Ripple from continuing to provide services. Please disclose whether Ripple has obtained
                                            all required licenses and is in compliance with applicable regulations, to the extent known.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 54 of the Amended Registration Statement
to disclose that while we are not aware of any pending regulatory changes which would prevent our partner from continuing to provide
their services to our customers and believe it to have all relevant approvals or licenses therefor, we cannot provide any assurance in
that regard or that our partner would be able to respond to any regulatory changes in a manner which did not impact our business.

Greenberg
                                            Traurig, LLP

www.gtlaw.com

Securities
                                            and Exchange Commission

Office
of Trade and Services

Division
of Corporation Finance

February
13, 2023

Page
4

8. Revise
                                            here and in the discussion of your business to update the percentages of revenue and transactions
                                            disclosed in this risk factor to reflect contributions by any additional customers as of
                                            September 30, 2022 that use the XRP funding process.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on pages 54 and 207 of the Amended Registration
Statement to update the percentages of revenue and transactions disclosed.

INFINT’s
amended and restated memorandum and articles of association provide that the courts of the Cayman Islands..., page 76

9. Please
                                            revise your risk factor to include that the Company’s exclusive forum provision does
                                            not apply to any action or suits brought to enforce any liability or duty created by the
                                            U.S. Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as
                                            amended.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 76 of the Amended Registration Statement
to include that the Company’s exclusive forum provision does not apply to any action or suits brought to enforce any liability
or duty created by the U.S. Securities Act of 1933, as amended, or the Securities Exchange Act of 1934, as amended.

Divestitures,
page 95

10. We
                                            note your written response and revised disclosures in response to comment 20. With regard
                                            to the additional ownership in Dynamic Indonesia, please disclose the purpose of increasing
                                            Seamless’ beneficial ownership of WalletKu. In addition, please indicate whether any
                                            of the existing shareholders who will receive equity interests in TNG (Asia) Ltd., Future
                                            Network Technology Investment Co., Ltd., and GEA Holdings Limited, are affiliates of Seamless.
                                            We also note your disclosure that the divestiture is not expected to materially adversely
                                            affect the revenue derived by Seamless from its relationships with these entities. Please
                                            clarify whether these entities will continue to be customers of Tranglo following the divestitures.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 96 of the Amended Registration Statement
to discuss the reason for the increase in Seamless’ beneficial ownership of WalletKu, clarify that TNG Asia and GEA will remain customers
following the Divestitures, and disclose that none of the shareholders of TNG Asia, FNTI and GEA following the Divestitures will
be affiliates of Seamless with the exception of Kong King Ong Alexander.

Greenberg
                                            Traurig, LLP

www.gtlaw.com

Securities
                                            and Exchange Commission

Office
of Trade and Services

Division
of Corporation Finance

February
13, 2023

Page
5

11. Please
                                            revise the diagrams on page 97 so that they are legible. As currently presented, the font
                                            is too small to read.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 97 of the Amended Registration Statement
so that the diagrams are legible.

12. We
                                            note various notes to the diagrams indicating that other shareholders have interests in the
                                            entities shown. Please revise to show these holdings in the diagram as opposed to include
                                            them as notes.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 97 of the Amended Registration Statement
to depict the minority holdings in the diagrams instead of the notes.

13. You
                                            disclose on page 97 that you have received approval of the Hong Kong Monetary Authority to
                                            divest TNG Asia. Please disclose the date of such approval.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 97 of the Amended Registration Statement
to disclose that Seamless received the approval by the Hong Kong Monetary Authority to divest TNG Asia on July 14, 2022.

Background
of the Business Combination, page 102

14. We
                                            note your revisions in response to comment 22. Please further revise your disclosure to expand
                                            upon InFinT’s investment mandate, including explaining the particular mandate and how
                                            the mandate influenced the structure of the business combination. Please also include any
                                            negotiations relating to the acquisition of ownership in Dynamic Indonesia and the reasons
                                            for the increase in ownership.

Response:
In response to the Staff’s comment, the Company has revised the disclosures on page 107 of the Amended Registration
Statement to expand disclosure regarding the Company’s investment mandate and how the mandate influenced the structure of the business
combination. In addition, the Company has revised the disclosure on page 110 of the Amended Registration Statement to include
negotiations relating to the acquisition of ownership in Dynamic Indonesia and the reasons for the increase in ownership.

Greenberg
                                            Traurig, LLP

www.gtlaw.com

Securities
                                            and Exchange Commission

Office
of Trade and Services

Division
of Corporation Finance

February
13, 2023

Page
6

15. Your
                                            disclosure on page 97 indicates that on November 29, 2022 you entered into an amendment to
                                            the Bu