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April 16, 2024
Swee Kheng Chua
Chief Executive Officer
Concorde International Group Ltd.
3 Ang Mo Kio Street 62, #01-49 LINK@AMK
Singapore 569139
Re:Concorde International Group Ltd.
Draft Registration Statement on Form F-1
Submitted March 20, 2024
CIK No. 0002001794
Dear Swee Kheng Chua:
            We have reviewed your draft registration statement and have the following comment(s).
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement 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 amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1 submitted March 20, 2024
Cover Page
1.We note your disclosure that you will be a “controlled company” under the Nasdaq
Capital Market or the NYSE American and that you intend to avail yourself of the
controlled company exemptions under the Nasdaq or NYSE rule. Please add this
disclosure to the prospectus summary and the description of your securities. Please also
add a risk factor to address the potential risks associated with being a controlled company.
Prospectus Summary, page 1
2.In the second paragraph of the Overview section starting on page 1, please revise the
following sentence to clarify the claim you are trying to convey: "With our technological
inventive solution, we deliver a higher level of security performance with headcount
uplifted of higher skillset, better reward as well as much sought after work-life balances
for the new era security workforce."

 FirstName LastNameSwee Kheng Chua
 Comapany NameConcorde International Group Ltd.
 April 16, 2024 Page 2
 FirstName LastNameSwee Kheng Chua
Concorde International Group Ltd.
April 16, 2024
Page 2
Our Products and Services, page 2
3.Please explain here, in plain English, how your i-Guarding services work and why they
confer the benefits you claim, such as manpower efficiency and enhanced service
delivery. In doing, please describe how your services are different from traditional
security services.
Our Growth Strategies, page 3
4.In the first bullet, please explain why and how monthly recurring revenue improves your
profitability. In addition, please address, if true, that to date you have not achieved
profitability (i.e., net income). In this regard, we note your financial statements reflect net
losses, and you auditor has expressed doubt about your ability to continue as a going
concern. Please make conforming revisions to the business section.
5.In the fourth bullet, please describe your plans to expand your geographical coverage and
export your business model beyond Singapore within the next 24 months. In addition,
please add a new subsection to the business section of the prospectus that discusses in
detail your plans for expansion. At a minimum, the discussion should name the markets
you have identified, set forth the expected timelines for expansion and quantify the
approximate capital requirements as well as the plans for funding those requirements.
Use of Proceeds, page 31
6.The description of the use of proceeds here differs from the description of the use of
proceeds on page 8 of the prospectus summary. Please revise your disclosure as necessary
so that it is consistent.
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
36
7.Please clarify the basis for your belief that you are one of the "leading integrated security
services providers in Singapore." Please also revise elsewhere, such as in the prospectus
summary and business sections, where you describe your company as "the leader" in the
markets you serve (see, e.g., page 3).
Liquidity and Capital Resources, page 41
8.Please discuss here the debt summarized in footnote 10 to the financial statements.
Related Party Transactions, page 68
9.Please provide all of the information required by Item 404 of Regulation S-K.
Consolidated Statement of Profit or Loss and Other Comprehensive Income, page F-4
10.It appears costs of sales excludes  depreciation and amortization, resulting in a

 FirstName LastNameSwee Kheng Chua
 Comapany NameConcorde International Group Ltd.
 April 16, 2024 Page 3
 FirstName LastName
Swee Kheng Chua
Concorde International Group Ltd.
April 16, 2024
Page 3
presentation of a "gross profit" subtotal before depreciation. For all periods presented,
please revise to remove the “gross profit” subtotal and relabel “cost of revenue” to “cost
of revenue, exclusive of depreciation shown separately below,” in accordance with the
guidance in SAB Topic 11B. You should similarly revise your Results of Operation
disclosures in MD&A.
Notes to the Consolidated Financial Statements
3. Significant accounting policies
3.4 Revenue recognition, page F-11
11.We note from your disclosure here that I-Gurarding services revenue including products,
installation and maintenance services are recognized at a point in time. Per the disclosure
in Note 14 on page F-29, I-Guarding revenues represents approximately 99% of total
revenues. This disclosure appears to be inconsistent with the table that presents "timing of
transfer of goods or services" on page F-29 which states that a majority of the revenue is
recognized over time. Please clarify or revise. In addition, we note per the disclosure on
page 37 that 85% of the revenues were generated by annual recurring contracts. Please tell
us how you determined your revenue recognition policy, including your consideration of
revenue recognition over time in accordance with IFRS 9 paragraphs 35–37.
General
12.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of
those communications.
            Please contact Scott Stringer at 202-551-3272 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Jenna Hough at 202-551-3063 or Dietrich King at 202-551-8071 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Louis A. Bevilacqua