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 March 28, 2025

Dezhi Liu
Chief Executive Officer
ORIENTAL RISE HOLDINGS LIMITED
No. 48 Xianyu Road
Shuangcheng Town, Zherong County
Ningde City, Fujian Province
People s Republic of China, 355399

 Re: ORIENTAL RISE HOLDINGS LIMITED
 Draft Registration Statement on Form F-1
 Submitted March 24, 2025
 CIK No. 0001964664
Dear Dezhi Liu:

 We have conducted a limited review of your draft registration statement
and have the
following comment(s).

 Please respond to this letter by providing any requested information
and by publicly
filing your registration statement and non-public draft submission on EDGAR. If
you do not
believe a comment applies to your facts and circumstances or do not believe an
amendment is
appropriate, please tell us why in your response.

 After reviewing the information you provide in response to this letter
and your filed
registration statement, we may have additional comments.

Draft Registration Statement on Form F-1
Cover Page

1. We note your disclosure that "[i]n the reporting periods presented and
as of the date of
 this prospectus, in addition to the US$1 million transferred from our
PRC subsidiaries
 to East Asia Enterprise, no cash and other asset transfers have occurred
among the
 Company and its subsidiaries; and no dividends or distributions of a
subsidiary has
 been made to the Company." Please clarify the amount transferred by each
PRC
 subsidiary to East Asia Enterprise, and reconcile this disclosure with
your disclosures
 on page 17 that "[i]n the reporting periods presented and as of the date
of prospectus,
 no cash and other asset transfers have occurred among the Company and
its
 subsidiaries."
 March 28, 2025
Page 2

General

2. In comparing your China-based company disclosure against your most
recent post-
 effective amendment to Form F-1 (File No. 333-274976) we note certain
changes to
 your disclosure appearing on the cover page, in your prospectus summary
and risk
 factor sections relating to legal and operational risks associated with
operating in the
 PRC. It is unclear to us that there have been changes in the regulatory
environment in
 the PRC since that post-effective amendment to Form F-1 was declared
effective on
 September 30, 2024, warranting revised disclosure to mitigate the
challenges you face
 and related disclosures. The Division's Sample Letters to China-Based
Companies
 sought specific disclosure relating to the risk that the PRC government
may intervene
 in or influence your operations at any time, or may exert control over
operations of
 your business, which could result in a material change in your
operations and/or the
 value of the securities you are registering for sale. We remind you
that, pursuant to
 federal securities rules, the term control (including the terms
controlling,
 controlled by, and under common control with ) as defined in
Securities Act Rule
 405 means the possession, direct or indirect, of the power to direct
or cause the
 direction of the management and policies of a person, whether through
the ownership
 of voting securities, by contract, or otherwise. The Sample Letters
also sought
 specific disclosures relating to uncertainties regarding the enforcement
of laws and
 that the rules and regulations in China can change quickly with little
advance
 notice. We do not believe that your revised disclosure conveys the same
 risk. Please restore your disclosures in these areas to the disclosures
as they existed in
 the post-effective amendment to Form F-1 effective as of September 30,
2024.
 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.

 We also remind you that your registration statement must be on file no
later than 48
hours prior to the requested effective date and time. 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.

 Please contact Juan Grana at 202-551-6034 or Margaret Sawicki at
202-551-7153
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Joe Laxague, Esq.
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