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May 15, 2023
Thomas Tam
Chief Executive Officer
Solowin Holdings, Ltd.
Room 1910-1912A, Tower 3
China Hong Kong City
33 Canton Road
Tsim Sha Tsui, Kowloon
Hong Kong
Re:Solowin Holdings, Ltd.
Registration Statement on Form F-1
Filed April 28, 2023
File No. 333-271525
Dear Thomas Tam:
            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 F-1 filed April 28, 2023
General
1.Please revise your filing to include audited financial statements required by Item 8.A.4 of
Form 20-F.  Alternately, please file a representation as an exhibit to your filing that states
that you are not required to comply with the 12-month requirement of audited financial
statements in any other jurisdiction outside the United States and that complying with the
12-month requirement is impracticable or involves undue hardship.  Refer to Instruction 2
of Item 8.A.4 of Form 20-F.

 FirstName LastNameThomas Tam
 Comapany NameSolowin Holdings, Ltd.
 May 15, 2023 Page 2
 FirstName LastName
Thomas Tam
Solowin Holdings, Ltd.
May 15, 2023
Page 2
            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.
            You may contact Shannon Davis at (202) 551-6687 or John Spitz at (202) 551-3484 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Robert Arzonetti at (202) 551-8819 or Susan Block at (202) 551-3210 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Kevin Sun