SecProbe.io

CORRESP
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    Monica J. Shilling, P.C.

    To Call Writer Directly:

    +1 310 552 4355

    monica.shilling@kirkland.com

    2049 Century Park East

    Los Angeles, CA 90067

    United States

    +1 310 552 4200

    www.kirkland.com

    Facsimile:

    +1 310 552 5900

March 9,
2023

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549-3628

    Attention:
    Ms. Kimberly A. Browning

    Mr. Michael Spratt

    Re:
    Ares Strategic Income Fund
 Registration Statement on Form N-2
 File Nos. 333-264145 and 814-01512

Ladies and Gentlemen:

This letter is sent on behalf
of Ares Strategic Income Fund (the “Fund”) in response to the comments of the Staff (the “Staff”)
of the United States Securities and Exchange Commission (the “SEC” or “Commission”) communicated
via teleconference to Kim Kaufman and Sarah Yang of Kirkland & Ellis LLP on February 23, 2023 regarding Pre-Effective Amendment
No. 3 to the Fund’s Registration Statement on Form N-2 (the “Registration Statement”).

Please note that the Fund
today filed with the Commission Pre-Effective Amendment No. 4 to the Registration Statement reflecting, among other things, the revisions
set forth below.

For convenience, we have set
forth below, in italics, the text of the Staff’s comment prior to each of the Fund’s responses. Capitalized terms used but
not defined herein have the meanings set forth in the Registration Statement. We acknowledge that the Fund 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. Please
note that revisions with respect to one portion of the Registration Statement are applicable to all similar portions of the Registration
Statement.

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    Securities and Exchange Commission

    March 9, 2023

    Page 2

 1. Comment: In connection with the acceptance of subscription orders, please supplementally provide
the Staff with your analysis of Rule 10b-9 and Rule 15c2-4 under the Securities Exchange Act of 1934, as amended, with respect
to this offering.

Response:
The Fund respectfully advises the Staff that Rule 10b-9 is not applicable to the Fund’s offering pursuant to the
Registration Statement because the Fund’s Common Shares are not being offered on an “all-or-none” basis or on any
other basis whereby all or part of the consideration paid for such Common Shares will be refunded to the purchaser if
all or some of the Common Shares are not sold. Rule 10b-9(a) is applicable only to securities being offered on
an “all-or-none” basis or on any other basis whereby all or part of the consideration paid for any such security will be
refunded to the purchaser if all or some of the securities are not sold. As noted on the cover pages and pages 11 and 144
of the Prospectus, the Fund’s Common Shares are being offered on a “best-efforts” basis, which means that the
Fund’s intermediary manager will use its best efforts to sell the Common Shares in this offering, but is not obligated to
purchase or sell any specific amount of the Common Shares. Further, the Fund respectfully advises the Staff that there is no minimum
offering condition with respect to this offering that could result in the consideration paid for any such Common Shares to be
refunded to the purchaser if all or some of the Common Shares are not sold.

Further, the Fund advises the Staff
that investors’ funds being held in a non-interest bearing account prior to acceptance by the Fund is in accordance with Rule 15c2-4.

Rule 15c2-4(a) requires any
broker, dealer or municipal securities dealer participating in any distribution of securities to promptly transmit the money or other
consideration received to the persons entitled thereto. Rule 15c2-4(b) further requires any broker, dealer or municipal securities
dealer participating in a distribution which contemplates that payment is not to be made to the person on whose behalf the distribution
is being made until some further event or contingency occurs to: (1) promptly deposit money or other consideration into a separate
bank account, as agent or trustee for the persons who have the beneficial interests therein, until the appropriate event or contingency
has occurred, and then promptly transmit or return the funds to the persons entitled thereto; or (2) promptly transmit such funds
to a bank which has agreed in writing to hold all such funds in escrow for the persons who have the beneficial interests therein and to
transmit or return such funds directly to the persons entitled thereto when the appropriate event or contingency has occurred.

As noted on page 149 of the Prospectus,
subscriptions to purchase the Fund’s Common Shares may be made on an ongoing basis, but investors may only purchase the Fund’s
Common Shares pursuant to accepted subscription orders as of the first day of the applicable month, and to be accepted, a subscription
request must be made with a completed and executed subscription agreement in good order, including satisfying any additional requirements
imposed by the investor’s broker, and payment of the full purchase price of the Fund’s Common Shares being subscribed at
least five business days prior to the first day of the month (unless waived by the intermediary manager). Upon receipt of an investor’s
purchase price for the Fund’s Common Shares, such purchase price will be promptly transmitted a non-interest-bearing account at
UMB Bank, N.A. (“UMB Bank”). UMB Bank has agreed to hold all such funds until the end of each month when an investor’s
subscription order is accepted or rejected, and to transmit or return such funds directly to the Fund or to the investor, as applicable,
when the Fund has either accepted or rejected such investor’s subscription, as applicable.

    Securities and Exchange Commission

    March 9, 2023

    Page 3

The Fund advises the Staff that, prior
to the Fund’s acceptance of an investor’s subscription, such investor’s funds will be held in a non-interest bearing
account at UMB Bank, N.A., which has agreed in writing to hold all such funds in escrow for the persons who have the beneficial interests
therein and to transmit or return such funds directly to the persons entitled thereto when the Fund has accepted or rejected such investor’s
subscription agreement, as applicable.

 2. Comment: We note the following sentence in footnote 3 to the pricing table: “Prior to
the Fund’s receipt and acceptance of the subscription orders effective as of the first day of the applicable month, proceeds from
sales of our Common Shares will be placed in a non-interest-bearing account at UMB Bank, N.A., in accordance with Rule 15c2-4 under
the Exchange Act.” Please provide additional specificity with respect to the requirements of Rule 15c2-4, including a reference
to Rule 15c2-4(b) and an explanation of the promptness policies that the Fund has in place with respect to scenarios that may
ensue.

Response:
The Fund advises the Staff that it has removed the disclosures regarding the escrow account from footnote 3 to the pricing table to remove
duplicative disclosures. Further, in response to the Staff’s comment, the Fund has revised its disclosures on pages 12, 34,
149 and 150 of the Prospectus by adding the bolded underlined text and deleting the text that is struck through below:

Prior
to our receipt and acceptance of the subscription orders effective as of the first day of the applicable month, proceeds from sales of
our Common Shares will be placed in a non-interest-bearing account at UMB Bank, N.A. under
the control of our transfer agent, DST Asset Manager Solutions, Inc., until we accept or reject such subscription order.
in In accordance with Rule 15c2-4 under the Exchange
Act, when we determine to accept or reject such subscription, such proceeds will be transmitted
to us or returned to the investor promptly, as applicable. Upon our acceptance of a shareholder’s subscription, such proceeds will
be transferred by our transfer agent into an account maintained by our custodian, U.S. Bank Trust Company, National Association.
If a purchase order is received less than five business days prior to the first day of the month, unless waived by the intermediary manager,
the purchase order will be held in a non-interest-bearing account and executed in the next month’s closing at the transaction price
applicable to that month. The proceeds will be released to us once the investor’s order is accepted as described in this
prospectus.

* * *

    Securities and Exchange Commission

    March 9, 2023

    Page 4

Investors who meet the suitability
standards described herein may purchase Common Shares. See “Suitability Standards” in this prospectus. Investors seeking to
purchase Common Shares must proceed as follows:

.
. . ● Deliver a check, submit a wire transfer, instruct your broker to make payment from your brokerage account or otherwise deliver
funds for the full purchase price of the Common Shares being subscribed for along with the completed subscription agreement to the participating
broker. Checks should be made payable, or wire transfers directed, to “Ares Strategic Income Fund.” Such
participating broker shall promptly transmit such funds directly to the account at UMB Bank, N.A. established for the Fund.
For Class S and Class D shares, after you have satisfied the applicable minimum purchase requirement of $2,500, additional purchases
must be in increments of $500. For Class I shares, after you have satisfied the applicable minimum purchase requirement of $1,000,000,
additional purchases must be in increments of $500, unless such minimums are waived by the intermediary manager. The minimum subsequent
investment does not apply to purchases made under our distribution reinvestment plan.

* * *

If
for any reason we reject the subscription, or if the subscription request is canceled before it is accepted or withdrawn as described
below, we will return the subscription agreement and DST Asset Manager Solutions, Inc.,
our transfer agent, will return the related funds, without interest or deduction, within ten business days promptly
after such rejection, cancellation or withdrawal.

 3. Comment: Please provide risk factors attendant to the non-interest bearing account (i.e., the
risk of funds being unavailable to investors if the offer is terminated or the risk of subscription orders not being accepted).

Response:
The Fund advises the Staff that it has added the following risk factor to page 34 of the Prospectus:

We will not invest the proceeds
from sales of our Common Shares in an interest-bearing account. Accordingly, if your subscription order is rejected, you will not be entitled
to any interest.

Prior to our receipt and acceptance
of the subscription orders effective as of the first day of the applicable month, proceeds from sales of our Common Shares will be placed
in a non-interest-bearing account at UMB Bank, N.A. under the control of our transfer agent, DST Asset Manager Solutions, Inc., until
we accept or reject such subscription order. In accordance with Rule 15c2-4 under the Exchange Act, when we determine to accept or
reject such subscription, such proceeds will be transmitted to us or returned to the investor promptly, as applicable. Upon our acceptance
of a shareholder’s subscription, such proceeds will be transferred by our transfer agent into an account maintained by our custodian,
U.S. Bank Trust Company, National Association. If a purchase order is received less than five business days prior to the first day of
the month, unless waived by the intermediary manager, the purchase order will be held in a non-interest-bearing account and executed in
the next month’s closing at the transaction price applicable to that month.

    Securities and Exchange Commission

    March 9, 2023

    Page 5

We may not accept your subscription
order, and can reject your subscription order for any reason, even if a prospective investor meets the minimum suitability requirements
outlined in our prospectus. If for any reason we reject the subscription, or if the subscription request is canceled before it is accepted
or withdrawn as described in “How to Subscribe”, we will return the subscription agreement and DST Asset Manager Solutions, Inc.,
our transfer agent, will return the related funds, without interest or deduction, promptly after such rejection, cancellation or withdrawal.
Accordingly, if your subscription is rejected or cancelled prior to our acceptance, you will receive the amount of proceeds sent to UMB
Bank, N.A. to purchase our Common Shares, without any additional interest that you may have earned if you invested funds in other investments.
We also reserve the right to terminate this offering at any time, including in any state in which our registration is not renewed or otherwise
extended annually, in which case any funds in connection with subscription orders that have not been accepted will be returned to you
without interest.

 4. Comment: Please supplementally confirm to the Staff that the disclosure in the Fund’s
operating agreements, subscription agreement and non-interest bearing account agreement is consistent with respect to the returns or refunds
of funds, per the requirements of Rule 10b-9 and Rule 15c2-4(b), as applicable.

Response:
The Fund confirms that the disclosure in its operating agreements, subscription agreement and non-interest bearing account agreement
(i.e., transfer agent agreement) is consistent with respect to the returns or refunds of funds, per the requirements of
Rule 10b-9 and Rule 15c2-4(b), as applicable, and appropriate disclosure is included in the Registration Statement.

    Securities and Exchange Commission

    March 9, 2023

    Page 6

 5. Comment: Please confirm that the related costs under the non-interest bearing account agreement
are disclosed in the fee table, including a description of who bears these costs. If Common Shareholders will bear these costs, directly
or indirectly, please disclose this in plain English. Please file the non-interest bearing account agreement as an exhibit to the Registration
Agreement.

Response:
The Fund advises the Staff that costs related to the non-interest bearing account are included under our Services Agreement with our transfer
agent, DST Asset Manager Solutions, Inc. Footnote #8 to the fee table on page 22 of the Prospectus has been revised as follows:

“Other expenses” includes
our overhead expenses, including payments under our administration agreement based on our allocable portion of overhead and other expenses
incurred by our administrator and transfer agent in performing theirits
obligations under the administration agreement and transfer agency agreement, respectively,
and our organization and offering expenses and income taxes.

The Services Agreement with our transfer
agent is filed as Exhibit (k)(2) to our Registration Statement.

 6. Comment: Please disclose which entity will accept purchase payments from investors.

Response:
Disclosure outlining the payment mechanics of subscription orders is included under “How to Subscribe.” Please refer to the
response to Staff Comment #2 for the disclosure added to the Registration Statement.

 7. Comment: We note that references to an escrow account are included in Notes 4 and 6 to the Fund’s
seed financial statements, but have been deleted elsewhere in the Registration Statement. Please revise this disclosure for accuracy.

Response:
This disclosure has been deleted, as the financial statements included in the Registration Statement have been updated.

 8. Comment: Please update the financial statements included in the Registration Statement pe