SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 29, 2025

Kai Cheong Wong
Chief Executive Officer
AsiaFIN Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail
50250 Kuala Lumpur, Malaysia

 Re: AsiaFIN Holdings Corp.
 Form 10-K for Fiscal Year Ended December 31, 2024
 File No. 000-56421
Dear Kai Cheong Wong:

 We have completed our review of your filings. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 AsiaFIN
Holdings Corp.

 Suite
30.02, 30th Floor, Menara KH (Promet)

 Jalan
Sultan Ismail

 50250
Kuala Lumpur

 Malaysia

 July
28, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Suying Li and Rufus Decker

 Re:
 AsiaFIN
 Holdings Corp.
 Form
 10-K for Fiscal Year Ended December 31, 2024
 Item
 2.02 Form 8-K filed June 3, 2025
 Response
 dated July 9, 2025
 File
 No. 000-5642.

 Ladies
and Gentlemen:

 By
letter dated July 23, 2025, the staff (the " Staff ," " you " or " your ") of the
U.S. Securities and Exchange Commission (the " Commission ") provided AsiaFIN Holdings Corp. (the " Company ,"
" we ," " us " or " our ") with its further comment to the Company's Form 8-K
filed on June 3, 2025. We are in receipt of your letter and we respectfully set forth below our response to your comment. For your convenience,
the comment is listed below, followed by the Company's response.

 Item
2.02 Form 8-K filed June 3, 2025

 Exhibit
99.1

 1. We
 read your response to prior comment 2. Please confirm that you will include directly in future
 Item 2.02 Forms 8-K all of the disclosures required by Item 10(e)(1)(i) of Regulation S-K
 for each non-GAAP measure presented, regardless of whether a non-GAAP measure is also presented
 in a Form 10-K or Form 10-Q. Refer to Instruction 2 to Item 2.02 of Form 8-K and Question
 102.10(a) of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations.

 Response:
 We hereby confirm that we will include directly in future Item 2.02 Forms 8-K all of the disclosures required by Item 10(e)(1)(i)
of Regulation S-K for each non-GAAP measure presented, regardless of whether a non-GAAP measure is also presented in a Form 10-K or Form
10-Q.

 Thank
you for the opportunity to respond to your comment. If you have additional questions or comments, please contact the undersigned at kcwong@asiafingroup.com
or +60 123733783.

 Very
truly yours,

 /s/
 Kai Cheong Wong

 Kai
 Cheong Wong

 Chief
 Executive Officer

<DOCUMENT>
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<TEXT>
 July 23, 2025

Kai Cheong Wong
Chief Executive Officer
AsiaFIN Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail
50250 Kuala Lumpur, Malaysia

 Re: AsiaFIN Holdings Corp.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Item 2.02 Form 8-K filed June 3, 2025
 Response dated July 9, 2025
 File No. 000-56421
Dear Kai Cheong Wong:

 We have reviewed your July 9, 2025 response to our comment letter and
have the
following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our June 30,
2025 letter.

Item 2.02 Form 8-K filed June 3, 2025
Exhibit 99.1

1. We read your response to prior comment 2. Please confirm that you will
include
 directly in future Item 2.02 Forms 8-K all of the disclosures required
by Item
 10(e)(1)(i) of Regulation S-K for each non-GAAP measure presented,
regardless of
 whether a non-GAAP measure is also presented in a Form 10-K or Form
10-Q. Refer
 to Instruction 2 to Item 2.02 of Form 8-K and Question 102.10(a) of the
Non-GAAP
 Financial Measures Compliance and Disclosure Interpretations.
 July 23, 2025
Page 2

 Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769
if you
have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 AsiaFIN
Holdings Corp.

 Suite
30.02, 30th Floor, Menara KH (Promet)

 Jalan
Sultan Ismail

 50250
Kuala Lumpur

 Malaysia

 July
9, 2025

 United
States Securities and Exchange Commission

 Division
of Corporation Finance

 Office
of Trade & Services

 100
F Street, N.E.

 Washington,
D.C. 20549

 Attention:
Suying Li and Rufus Decker

 Re:
 AsiaFIN
 Holdings Corp.

 Form
 10-K for Fiscal Year Ended December 31, 2024

 Item
 2.02 Form 8-K filed June 3, 2025

 File
 No. 000-56421

 Ladies
and Gentlemen:

 By
letter dated June 30, 2025, the staff (the " Staff ," " you " or " your ") of the
U.S. Securities and Exchange Commission (the " Commission ") provided AsiaFIN Holdings Corp.(the " Company ,"
" we ," " us " or " our ") with its comments to the Company's Annual Report
on Form 10-K for fiscal year ended December 31, 2024 filed on March 25, 2025 and its Current Report on Form 8-K filed on June 3, 2025.
We are in receipt of your letter and we respectfully set forth below our responses to your comments. For your convenience, the comments
are listed below, followed by the Company's responses.

 Form
10-K for Fiscal Year Ended December 31, 2024

 Audited
Financial Statements

 Note
14. Income Taxes, page F-16

 1.
You state on page F-12 that you have adopted ASU 2023-09 in fiscal year ended December 31, 2024. Please tell us your consideration of
providing the disclosure required in ASC 740-10-50-11 through 50-12 and 50-23.

 Response:

 We
have considered and reviewed ASC 740-10-50-11 through 50-12 and 50-23 and their application to our audited financial statements as of
and for the fiscal year ended December 31, 2024. We respectfully submit that upon such consideration and review, we confirm that we have
not provided any further disclosures as we have deemed any such disclosures not material in the context of the company and our financial
statements. As disclosed in Note 14 to our audited financial statements as of and for the fiscal year ended December 31, 2024, we are
not subject to income taxes in the British Virgin Islands or in Labuan, Malaysia (an offshore financial center established by Malaysia).
Moreover, we have no taxable income in the United States and, as of December 31, 2024, we have cumulative net operating losses (NOLs)
of $933,440. Consequently, for the fiscal year ended December 31, 2024, we had a tax liability only for Malaysian (non-offshore financial
center) taxes. Accordingly, we have determined that no additional disclosures were therefore required.

 Item
2.02 Form 8-K filed June 3, 2025

 Exhibit
99.1

 2.
Your presentation of EBITDA appears to be a non-GAAP measure. Please provide the disclosures required in Item 10(e) of Regulation S-K.

 Response:

 We
note Item 10(e) of Regulation S-K and the disclosures required thereby regarding non-GAAP financial measures. In our press releases dated
May 13, 2025 and the correction dated May 23, 2025 (together the "Press Releases"), both of which were attached as exhibits
to the Current Report on Form 8-K filed with the Commission on June 3, 2025, we cited several financial measures relating to our financial
results for the quarter ended March 31, 2025, one of which was "EBITDA", which we acknowledge is a non-GAAP financial measure
within the meaning of Item 10(e)(2) of Regulation S-K.

 We
note that the presentation of EBITDA in the Press Releases (in compliance with Item 10(e)(1)(i) of Regulation S-K) did not give such
non-GAAP financial measure any greater prominence than that given to the directly comparable financial measure or measures calculated
and presented in accordance with GAAP. The bulleted list where the EBITDA measure was set forth also included the items "net loss",
"net loss attributable to common shareholders" and "total comprehensive loss", each of which is a GAAP measure
derived directly from the unaudited condensed consolidated statements of operations and comprehensive loss for the three months ended
March 31, 2025 and 2024, filed with the Commission our Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2025 filed
with the Commission on May 13, 2025. Each of these measures are directly comparable to the non-GAAP financial measure presented in the
Press Releases.

 We
note that such quarterly report on Form 10-Q did not contain a reconciliation of the differences between EBITDA with the most directly
comparable financial measure or measures calculated and presented in accordance with GAAP nor a statement disclosing the reasons why
we believe that presentation of EBITDA provides useful information to investors regarding our financial condition and results of operations,
in accordance with Items 10(e)(1)(i)(B) and (C) of Regulation S-K.

 We
note as well that the EBITDA of -$465,000 disclosed in the press release for the three months ended March 31, 2025 did not materially
differ from the total comprehensive loss of $468,000 reported on our unaudited condensed consolidated statements of operations and comprehensive
loss for the three months ended March 31, 2025.

 Going
forward, we undertake to (1) exclude non-GAAP financial measures from our earnings press releases if such measures and the disclosures
required by Item 10(e) of Regulation S-K in respect of such financial measures are not included in the related Quarterly Report on Form
10-Q or the Annual Report on Form 10-K or (2) if such measures are included, provide (i) a reconciliation of any non-GAAP financial measures
presented with the most directly comparable financial measure or measures calculated and presented in accordance with GAAP and (ii) a
statement disclosing the reasons why we believe that presentation of any such non-GAAP financial measure provides useful information
to investors regarding our financial condition and results of operations.

 Thank
you for the opportunity to respond to your comments on our filings. If you have additional questions or comments, please contact the
undersigned at kcwong@asiafingroup.com or +60 123733783.

 Very
truly yours,

 /s/
 Kai Cheong Wong

 Kai Cheong Wong

 Chief Executive Officer

<DOCUMENT>
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<TEXT>
 June 30, 2025

Kai Cheong Wong
Chief Executive Officer
AsiaFIN Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail
50250 Kuala Lumpur, Malaysia

 Re: AsiaFIN Holdings Corp.
 Form 10-K for Fiscal Year Ended December 31, 2024
 Item 2.02 Form 8-K filed June 3, 2025
 File No. 000-56421
Dear Kai Cheong Wong:

 We have reviewed your filings and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2024
Audited Financial Statements
Note 14. Income Taxes, page F-16

1. You state on page F-12 that you have adopted ASU 2023-09 in fiscal year
ended
 December 31, 2024. Please tell us your consideration of providing the
disclosure
 required in ASC 740-10-50-11 through 50-12 and 50-23.
Item 2.02 Form 8-K filed June 3, 2025
Exhibit 99.1

2. Your presentation of EBITDA appears to be a non-GAAP measure. Please
provide the
 disclosures required in Item 10(e) of Regulation S-K.
 June 30, 2025
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.

 Please contact Suying Li at 202-551-3335 or Rufus Decker at 202-551-3769
if you
have any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
January 6, 2023
Kai Cheong Wong
Chief Executive Officer, President, Director, Secretary and Treasurer
AsiaFIN Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail
50250 Kuala Lumpur
Malaysia
Re:AsiaFIN Holdings Corp.
Form 10-KT for the Transition Period Ended December 31, 2021
Filed March 30, 2022
File No. 333-251413
Dear Kai Cheong Wong:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
filename1.htm

January
05, 2023

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

Division
of Corporations Finance

100
F Street, NE

Washington,
D.C. 20549

RE:
AsiaFIN Holdings Corp.

Form
10-KT for the Transition Period Ended December 31, 2021

Filed
March 30, 2022

File
No. 333-251413

To
all the good men and women of the SEC

We
received your letter date December 1, 2022 with regards to the above mentioned you have additional comment on our latest 10-KT filing:

Form
10-KT for the Transition Period Ended December 31, 2021

SEC
question 1:

Item
9A. Controls and Procedures, page 18

  1.
  Please
  disclose the conclusions of your principal executive officer and principal financial officer regarding the effectiveness of your disclosure
  controls and procedures as of the end of the period covered by this report. Refer to Item 307 of Regulation S-K.

AsiaFIN
Response:

ITEM
9A. CONTROLS AND PROCEDURES

Evaluation
of Disclosure Controls and Procedures

As
of the end of the period covered by this Report, our management carried out an evaluation, under the supervision and with the participation
of our management, including our principal executive officer and principal financial officer, of the effectiveness of the design and
operation of our disclosure controls and procedures (as defined in the Exchange Act Rules 13a-15(e) and 15d-15(e)). Based on the foregoing
evaluation, our principal executive officer and principal financial officer concluded that, as of December 31, 2021, our disclosure controls
and procedures were not effective at the reasonable assurance level due to the material weaknesses described below.

Management’s
Report on Internal Control over Financial Reporting

Our
management, including our principal executive officer and principal financial officer, is responsible for establishing and maintaining
adequate internal control over financial reporting. Internal control over financial reporting is defined in Rule 13a-15(f) or 15d-15(f)
promulgated under the Exchange Act as a process designed by, or under the supervision of, the company’s principal executive and
principal financial officers and effected by the company’s board of directors, management and other personnel, to provide reasonable
assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance
with accounting principles generally accepted in the United States of America and includes those policies and procedures that:

    ●
    Pertain
    to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets
    of the company;

    ●
    Provide
    reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with
    accounting principles generally accepted in the United States of America and that receipts and expenditures of the company are being
    made only in accordance with authorizations of management and directors of the company; and

    ●
    Provide
    reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the company’s
    assets that could have a material effect on the financial statements.

Because
of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Projections of any evaluation
of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that
the degree of compliance with the policies or procedures may deteriorate. All internal control systems, no matter how well designed,
have inherent limitations. Therefore, even those systems determined to be effective can provide only reasonable assurance with respect
to financial statement preparation and presentation. Because of the inherent limitations of internal control, there is a risk that material
misstatements may not be prevented or detected on a timely basis by internal control over financial reporting. However, these inherent
limitations are known features of the financial reporting process. Therefore, it is possible to design into the process safeguards to
reduce, though not eliminate, this risk.

As
of December 31, 2021, our management, including our principal executive officer and principal financial officer, assessed the effectiveness
of our internal control over financial reporting based on the criteria for effective internal control over financial reporting established
in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”)
and SEC guidance on conducting such assessments. Based on such evaluation, the Company’s management, including our principal executive
officer and principal financial officer, concluded that, during the period covered by this Report, internal controls over financial reporting
were not effective. This was due to deficiencies that existed in the design or operation of our internal controls over financial reporting
that adversely affected our internal controls and that may be considered to be material weaknesses.

Identified
Material Weakness

A
material weakness in internal control over financial reporting is a control deficiency, or combination of control deficiencies, that
results in more than a remote likelihood that a material misstatement of the financial statements will not be prevented or detected.

Our
Management, including our principal executive officer and principal financial officer, identified the following material weakness during
its assessment of internal controls over financial reporting as of December 31, 2021:

    1.
    We
    do not have adequate resources on finance personnel - Insufficient full-time personnel with appropriate levels of accounting
    knowledge and experience to monitor the daily recording of transactions, address accounting issues and to prepare and review financial
    statements and submit SEC filing related documents.

    2.
    We
    do not have adequate segregation of duties and effective risk assessment – Lack of segregation of duties and effective
    risk assessment may cause the Company to face the likelihood of fraud or theft, due to poor oversight, governance and review to detect
    errors.

Accordingly,
the Company concluded that these control deficiencies resulted in a reasonable possibility that a material misstatement of the annual
or interim financial statements will not be prevented or detected on a timely basis by the company’s internal controls.

Management’s
Remediation Initiatives

To
further strengthen the Company’s internal controls, we plan to initiate the following measures going forward:

    1.
    We
    intend to add staff members to our management team for making sure that information required to be disclosed in our reports filed
    and submitted under the Exchange Act is recorded, processed, summarized and reported as and when required and will the staff members
    will have segregated responsibilities with regard to these responsibilities.

    2.
    We
    plan to create a position to segregate duties consistent with control objectives and will increase our personnel resources and technical
    accounting expertise within the accounting function. The accounting personnel is responsible for reviewing the financing activities,
    facilitate the approval of the financing, record the information regarding the financing, and submit SEC filing related documents
    to our legal counsel in order to comply with the filing requirements of SEC.

We
created a position of finance manager and appointed our finance manager on September 1, 2021.

We
anticipate that the rest of initiatives will be at least partially, if not fully, implemented by the end of fiscal year 2021.

Changes
in internal controls over financial reporting

There
was no significant change in our internal controls over financial reporting that occurred
during the period covered by this Report, which has materially affected, or is reasonably likely to materially affect, our internal controls
over financial reporting:

This
annual report does not include an attestation report of the Company’s registered independent public accounting firm regarding internal
control over financial reporting. Management’s report was not subject to attestation by the Company’s registered independent
public accounting firm pursuant to rules of the Securities and Exchange Commission that permit the Company to provide only management’s
report in this Annual Report on Form 10-KT.

SEC
question 2:

Signatures,
page 27

  2.
  Please
  ensure that your Forms 10-K are signed by the registrant, and on behalf of the registrant by its principal executive officer, its principal
  financial officer, its controller or principal accounting officer, and by at least the majority of the board of directors. Any person
  who occupies more than one of the specified positions shall indicate each capacity in which he signs the report. Refer to General Instruction
  D(2) of Form 10-K. Similarly ensure that your Forms 10-Q are signed on your behalf by a duly authorized officer and by your principal
  financial officer or your chief accounting officer. Refer to General Instruction E of Form 10-Q. Also, ensure that your Forms 10-K
  and 10-Q include under Exhibits 31 and 32 the required certifications from both your principal executive officer and your principal
  financial officer. Refer to Item 601(b)(31) and (32) of Regulation S-K and Rules 15d-14(a) and (b) of the Exchange Act.

AsiaFIN
Response:

Our
filing was signed by our board of directors rather than principal executive and principal financial officers as per Item 307 of Regulation
S-K. The signing was disregarded due to our principal financial officer only came onboard in September 2021, and we have been following
the same format on signatures even though the internal control on financial reporting procedures has been in place.

We
assure compliance to Item 307 of Regulation S-K, on signing by principal executive and principal financial officer for all future filing.
We filed sample of signatures for all future filing for 10K and 10Q as Exhibit A to this letter for your reference.

You
may contact me if you require further information. Thank you and sorry for the inconvenience caused.

Date:
December 23, 2021

  By:
  /s/Wong
  Kai Cheong

  Wong
  Kai Cheong

  Chief
  Executive Office, President, Secretary,

  Treasurer,
  and Director

  (Principal
  Executive Officer)

Exhibit
A

Sample
Signature on 10-K

SIGNATURES

Pursuant
to the requirements of Section 13 or 15(d) of the Securities Exchange Act 1934, the Registrant has duly caused this Report to be signed
on its behalf by the undersigned, hereunto duly authorized.

    ASIAFIN
    HOLDINGS CORP.

    Date:
    30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer, President, Director, Secretary,

Treasurer

Pursuant
to the requirements of the Securities Exchange Act of 1934, this Report has been signed by the following persons in the capacities and
on the dates indicated.

    Date:
    30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer,

    President,
    Director, Secretary and Treasurer

    (Principal
    Executive Officer)

    Date:
    30 March 2022
    By:
    /s/
    Cham Hui Yin

    Cham
    Hui Yin

    Finance
    Manager

    (Principal
    Financial Officer and Principal Accounting Officer)

    Date:
    30 March 2022
    By:
    /s/
    Seah Kok Wah

    Seah
    Kok Wah

    Director

Sample
Signature on 10-Q

SIGNATURES

Pursuant
to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by
the undersigned, thereunto duly authorized.

    AsiaFIN
    Holdings Corp

    (Name
    of Registrant)

    Date:
    May 11, 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
                                            Executive Officer,

    President,
    Director, Secretary and Treasurer

    (Principal
    Executive Officer)

    Date:
    May 11, 2022
    By:
    /s/
    Cham Hui Yin

    Cham
    Hui Yin

    Finance
    Manager

    (Principal
    Financial Officer and Principal

Accounting Officer)

Sample
Signature on Exhibit 31

EXHIBIT
31.1

CERTIFICATION

I,
Wong Kai Cheong, certify that:

1.
I have reviewed this annual report on Form 10-KT of AsiaFIN Holdings Corp. (the “Company”);

2.
Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the
period covered by this report;

3.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material
respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this
report;

4.
The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures
(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act
Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

    a.
    Designed
    such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision,
    to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others
    within those entities, particularly during the period in which this report is being prepared;

    b.
    Designed
    such internal control over financial reporting, or caused such internal control to be designed under our supervision, to provide
    reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
    in accordance with generally accepted accounting principles.

    c.
    Evaluated
    the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about
    the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation;
    and

    d.
    Disclosed
    in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s
    most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected,
    or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.
The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial
reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing
the equivalent functions):

    a.
    All
    significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are
    reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information;
    and

    b.
    Any
    fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s
    internal control over financial reporting.

    Date:
    30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer, President, Director,

Secr

CORRESP
1
filename1.htm

December
23, 2022

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

Division
of Corporations Finance

100
F Street, NE

Washington,
D.C. 20549

RE:
    AsiaFIN Holdings Corp.

Form
10-KT for the Transition Period Ended December 31, 2021

Filed
March 30, 2022

File
No. 333-251413

To
all the good men and women of the SEC

We
received your letter date December 1, 2022 with regards to the above mentioned you have additional comment on our latest 10-KT filing:

Form
10-KT for the Transition Period Ended December 31, 2021

SEC
question 1:

Item
9A. Controls and Procedures, page 18

  1.
  Please disclose the conclusions of your principal executive
officer and principal financial officer regarding the effectiveness of your disclosure controls and procedures as of the end of the period
covered by this report. Refer to Item 307 of Regulation S-K.

AsiaFIN
Response:

ITEM
9A. CONTROLS AND PROCEDURES

Disclosures
Control and Procedures

Our
management, including our principal executive officer and principal financial officer, is responsible for establishing and maintaining
adequate internal control over financial reporting. Internal control over financial reporting is defined in Rule 13a-15(f) or 15d-15(f)
promulgated under the Exchange Act as a process designed by, or under the supervision of, the company’s principal executive and
principal financial officers and effected by the company’s board of directors, management and other personnel, to provide reasonable
assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance
with accounting principles generally accepted in the United States of America and includes those policies and procedures that:

    ●
    Pertain
    to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of the assets
    of the company;

    ●
    Provide
    reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with
    accounting principles generally accepted in the United States of America and that receipts and expenditures of the company are being
    made only in accordance with authorizations of management and directors of the company; and

    ●
    Provide
    reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the company’s
    assets that could have a material effect on the financial statements.

Because
of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Projections of any evaluation
of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that
the degree of compliance with the policies or procedures may deteriorate. All internal control systems, no matter how well designed,
have inherent limitations. Therefore, even those systems determined to be effective can provide only reasonable assurance with respect
to financial statement preparation and presentation. Because of the inherent limitations of internal control, there is a risk that material
misstatements may not be prevented or detected on a timely basis by internal control over financial reporting. However, these inherent
limitations are known features of the financial reporting process. Therefore, it is possible to design into the process safeguards to
reduce, though not eliminate, this risk.

As
of December 31, 2021, our management, including our principal executive officer and principal financial officer, assessed the effectiveness
of our internal control over financial reporting based on the criteria for effective internal control over financial reporting established
in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”)
and SEC guidance on conducting such assessments. Based on such evaluation, the Company’s management, including our principal executive
officer and principal financial officer, concluded that, during the period covered by this Report, internal controls and procedures over
financial reporting were not effective. This was due to deficiencies that existed in the design or operation of our internal controls
over financial reporting that adversely affected our internal controls and that may be considered to be material weaknesses.

Identified
Material Weakness

A
material weakness in internal control over financial reporting is a control deficiency, or combination of control deficiencies, that
results in more than a remote likelihood that a material misstatement of the financial statements will not be prevented or detected.

Our
Management, including our principal executive officer and principal financial officer, identified the following material weakness during
its assessment of internal controls over financial reporting as of December 31, 2021:

    1.
    We
    do not have adequate resources on finance personnel - Insufficient full-time personnel with appropriate levels of accounting
    knowledge and experience to monitor the daily recording of transactions, address accounting issues and to prepare and review financial
    statements and submit SEC filing related documents.

    2.
    We
    do not have adequate segregation of duties and effective risk assessment – Lack of segregation of duties and effective
    risk assessment may cause the Company to face the likelihood of fraud or theft, due to poor oversight, governance and review to detect
    errors.

Accordingly,
the Company concluded that these control deficiencies resulted in a reasonable possibility that a material misstatement of the annual
or interim financial statements will not be prevented or detected on a timely basis by the company’s internal controls.

Management’s
Remediation Initiatives

To
further strengthen the Company’s internal controls, we plan to initiate the following measures going forward:

    1.
    We
    intend to add staff members to our management team for making sure that information required to be disclosed in our reports filed
    and submitted under the Exchange Act is recorded, processed, summarized and reported as and when required and will the staff members
    will have segregated responsibilities with regard to these responsibilities.

    2.
    We
    plan to create a position to segregate duties consistent with control objectives and will increase our personnel resources and technical
    accounting expertise within the accounting function. The accounting personnel is responsible for reviewing the financing activities,
    facilitate the approval of the financing, record the information regarding the financing, and submit SEC filing related documents
    to our legal counsel in order to comply with the filing requirements of SEC.

We
created a position of finance manager and appointed our finance manager on September 1, 2021.

We
anticipate that the rest of initiatives will be at least partially, if not fully, implemented by the end of fiscal year 2021.

Changes
in internal controls over financial reporting

There
was no significant change in our internal controls over financial reporting that occurred
during the period covered by this Report, which has materially affected, or is reasonably likely to materially affect, our internal controls
over financial reporting:

This
annual report does not include an attestation report of the Company’s registered independent public accounting firm regarding internal
control over financial reporting. Management’s report was not subject to attestation by the Company’s registered independent
public accounting firm pursuant to rules of the Securities and Exchange Commission that permit the Company to provide only management’s
report in this Annual Report on Form 10-KT.

SEC
question 2:

Signatures,
page 27

  2.
  Please ensure that your Forms 10-K are signed by the registrant,
and on behalf of the registrant by its principal executive officer, its principal financial officer, its controller or principal accounting
officer, and by at least the majority of the board of directors. Any person who occupies more than one of the specified positions shall
indicate each capacity in which he signs the report. Refer to General Instruction D(2) of Form 10-K. Similarly ensure that your Forms
10-Q are signed on your behalf by a duly authorized officer and by your principal financial officer or your chief accounting officer.
Refer to General Instruction E of Form 10-Q. Also, ensure that your Forms 10-K and 10-Q include under Exhibits 31 and 32 the required
certifications from both your principal executive officer and your principal financial officer. Refer to Item 601(b)(31) and (32) of
Regulation S-K and Rules 15d-14(a) and (b) of the Exchange Act.

AsiaFIN
Response:

Our
filing was signed by our board of directors rather than principal executive and principal financial officers as per Item 307 of Regulation
S-K. The signing was disregarded due to our principal financial officer only came onboard in September 2021, and we have been following
the same format on signatures even though the internal control on financial reporting procedures has been in place.

We
assure compliance to Item 307 of Regulation S-K, on signing by principal executive and principal financial officer for all future filing.
We filed sample of signatures for all future filing for 10K and 10Q as Exhibit A to this letter for your reference.

You
may contact me if you require further information. Thank you and sorry for the inconvenience caused.

Date:
December 23, 2022

    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Office, President, Secretary,

    Treasurer,
    and Director

    (Principal
    Executive Officer)

Exhibit
A

Sample
Signature on 10-K

SIGNATURES

Pursuant
to the requirements of Section 13 or 15(d) of the Securities Exchange Act 1934, the Registrant has duly caused this Report to be signed
on its behalf by the undersigned, hereunto duly authorized.

    ASIAFIN
HOLDINGS CORP.

    Date:
30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer, President, Director, Secretary, Treasurer

Pursuant
to the requirements of the Securities Exchange Act of 1934, this Report has been signed by the following persons in the capacities and
on the dates indicated.

    Date:
    30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer,

    President,
    Director, Secretary and Treasurer

    (Principal
    Executive Officer)

    Date:
    30 March 2022
    By:
    /s/
    Cham Hui Yin

    Cham
    Hui Yin

    Finance
    Manager

    (Principal
    Financial Officer)

    Date:
    30 March 2022
    By:
    /s/
    Seah Kok Wah

    Seah
    Kok Wah

    Director

Sample
Signature on 10-Q

SIGNATURES

Pursuant
to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by
the undersigned, thereunto duly authorized.

    AsiaFIN
    Holdings Corp

    (Name
    of Registrant)

    Date:
    May 11, 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer,

    President,
    Director, Secretary and Treasurer

    (Principal
    Executive Officer)

    Date:
    May 11, 2022
    By:
    /s/
    Cham Hui Yin

    Cham
    Hui Yin

    Finance
    Manager

    (Principal
    Financial Officer)

Sample
Signature on Exhibit 31

EXHIBIT
31.1

CERTIFICATION

I,
Wong Kai Cheong, certify that:

1.
I have reviewed this annual report on Form 10-KT of AsiaFIN Holdings Corp. (the “Company”);

2.
Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the
period covered by this report;

3.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material
respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this
report;

4.
The registrant’s other certifying officer and I are responsible for establishing and maintaining disclosure controls and procedures
(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control over financial reporting (as defined in Exchange Act
Rules 13a-15(f) and 15d-15(f)) for the registrant and have:

    a.
    Designed
    such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision,
    to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others
    within those entities, particularly during the period in which this report is being prepared;

    b.
    Designed
    such internal control over financial reporting, or caused such internal control to be designed under our supervision, to provide
    reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes
    in accordance with generally accepted accounting principles.

    c.
    Evaluated
    the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about
    the effectiveness of the disclosure controls and procedures, as of the end of the period covered by this report based on such evaluation;
    and

    d.
    Disclosed
    in this report any change in the registrant’s internal control over financial reporting that occurred during the registrant’s
    most recent fiscal quarter (the registrant’s fourth fiscal quarter in the case of an annual report) that has materially affected,
    or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and

5.
The registrant’s other certifying officer and I have disclosed, based on our most recent evaluation of internal control over financial
reporting, to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing
the equivalent functions):

    a.
    All
    significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are
    reasonably likely to adversely affect the registrant’s ability to record, process, summarize and report financial information;
    and

    b.
    Any
    fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s
    internal control over financial reporting.

    Date:
    30 March 2022
    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Officer, President, Director, Secretary, Treasurer

    (Principal
    Executive Officer)

EXHIBIT
31.2

CERTIFICATION

I,
Cham Hui Yin, certify that:

1.
I have reviewed this annual report on Form 10-KT of AsiaFIN Holdings Corp. (the “Company”);

2.
Based on my knowledge, this annual report does not contain any untrue statement of a material fact or omit to state a material fact necessary
to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the
period covered by this report;

3.
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material
respects the financial condition, results of operations and cash flows of the registrant as of, and for, the periods presented in this
report;

4.
The registrant’s other certifying

CORRESP
1
filename1.htm

December
15, 2022

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

Division
of Corporations Finance

100
F Street, NE

Washington,
D.C. 20549

    RE:

    AsiaFIN
    Holdings Corp.

Form
10-KT for the Transition Period Ended December 31, 2021

Filed
March 30, 2022

File
No. 333-251413

To
the men and women of the SEC:

Response
to your comment:

We
received your letter date December 1, 2022 with regards to the above mentioned you have additional comment on our latest 10-KT filing:

Form 10-KT for the Transition Period Ended December 31, 2021

SEC question 1:

Item 9A. Controls and Procedures, page 18

    1.
    Please
    disclose the conclusions of your principal executive officer and principal financial officer regarding the effectiveness of your
    disclosure controls and procedures as of the end of the period covered by this report. Refer to Item 307 of Regulation S-K.

AsiaFIN Response:

We are hereby providing our conclusions regarding the effectiveness of
our disclosure controls and procedures on our filling.

The
following personnel who operation the finance controls and procedures for the company. All individuals represent different functionality
of the business or has no absolute control nor overriding decisions making process. The segregation of duties has been clearly defined
and check and balance is being monitor in completing tasks.

Furthermore,
all filings are reviewed by the Board of Directors being those charges with governance. Subsequently, it is being review by external
PCAOB Auditors and consent is to be obtained prior to filing

    No.

    Name

    Position

    1

    Wong
    Kai Cheong

    CEO,
    President, Director, Secretary, Treasurer

    2

    Seah
    Kok Wah

    Director

    3

    Cham
    Hui Yin

    Finance
    Manager

The
following diagram display the procedures on our filing:

For the diagram, there are a maker and checkers
that implement checks and balances in the procedures on the preparation of financial statement and filing to reduce mistakes, prevent
improper behavior, or decrease the risk of centralization of power.

SEC question 2:

Signatures, page 27

    2.
    Please ensure that your
    Forms 10-K are signed by the registrant, and on behalf of the registrant by its principal executive officer, its principal financial
    officer, its controller or principal accounting officer, and by at least the majority of the board of directors. Any person who occupies
    more than one of the specified positions shall indicate each capacity in which he signs the report. Refer to General Instruction
    D(2) of Form 10-K. Similarly ensure that your Forms 10-Q are signed on your behalf by a duly authorized officer and by your principal
    financial officer or your chief accounting officer. Refer to General Instruction E of Form 10-Q. Also, ensure that your Forms 10-K
    and 10-Q include under Exhibits 31 and 32 the required certifications from both your principal executive officer and your principal
    financial officer. Refer to Item 601(b)(31) and (32) of Regulation S-K and Rules 15d-14(a) and (b) of the Exchange Act.

AsiaFIN Response:

Our
filing was signed by our board of directors rather
than principal executive and principal financial officers as per Item 307 of Regulation S-K. The signing was disregarded due to our principal
financial officer only came onboard in September 2021, and we have been following the same format on signatures even though the internal
control on financial reporting procedures has been in place.

We
assure compliance to Item 307 of Regulation S-K, on signing by principal executive and principal financial officer for all future filing.
You may contact me if you require further information.

Thank
you and sorry for the inconvenience caused.

    Date:
    December
15, 2022

    By:
    /s/
    Wong Kai Cheong

    Wong
    Kai Cheong

    Chief
    Executive Office, President, Secretary,

    Treasurer,
    and Director

United States securities and exchange commission logo
December 1, 2022
Kai Cheong Wong
Chief Executive Officer, President, Director, Secretary and Treasurer
AsiaFIN Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail
50250 Kuala Lumpur
Malaysia
Re:AsiaFIN Holdings Corp.
Form 10-KT for the Transition Period Ended December 31, 2021
Filed March 30, 2022
File No. 333-251413
Dear Kai Cheong Wong:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-KT for the Transition Period Ended December 31, 2021
Item 9A. Controls and Procedures, page 18
1.Please disclose the conclusions of your principal executive officer and principal financial
officer regarding the effectiveness of your disclosure controls and procedures as of the end
of the period covered by this report.  Refer to Item 307 of Regulation S-K.
Signatures, page 27
2.Please ensure that your Forms 10-K are signed by the registrant, and on behalf of the
registrant by its principal executive officer, its principal financial officer, its controller or
principal accounting officer, and by at least the majority of the board of directors.  Any
person who occupies more than one of the specified positions shall indicate each capacity
in which he signs the report.  Refer to General Instruction D(2) of Form 10-K.  Similarly

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFIN Holdings Corp.
 December 1, 2022 Page 2
 FirstName LastName
Kai Cheong Wong
AsiaFIN Holdings Corp.
December 1, 2022
Page 2
ensure that your Forms 10-Q are signed on your behalf by a duly authorized officer and by
your principal financial officer or your chief accounting officer.  Refer to General
Instruction E of Form 10-Q.  Also, ensure that your Forms 10-K and 10-Q include under
Exhibits 31 and 32 the required certifications from both your principal executive officer
and your principal financial officer.  Refer to Item 601(b)(31) and (32) of Regulation S-K
and Rules 15d-14(a) and (b) of the Exchange Act.
            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.
            You may contact Keira Nakada at 202-551-3659 or Rufus Decker at 202-551-3769 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

CORRESP
1
filename1.htm

March 29, 2021

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

Division of Corporations Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: AsiaFIN Holdings Corp.

Form S-1/A

Filed March 19, 2021

File No. 333-251413

To the men and women of the SEC:

Acceleration Request:

We, AsiaFIN Holdings Corp. (the “Registrant”)
hereby requests that the Securities and Exchange Commission take appropriate action to declare the above captioned Registration
Statement effective at the requested date of March 31, 2021 at 4 PM Eastern Standard Time or as soon as practicable thereafter.

In connection with this request, the Company acknowledges
that:

-Should the Commission or the staff, acting pursuant
to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

-The action of the Commission or the staff, acting
pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

-The Company may not assert staff comments and the
declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

Date: March 29, 2021

By: /s/Wong Kai Cheong

Wong Kai Cheong

Chief Executive Officer, President, Secretary,

Treasurer, and Director

United States securities and exchange commission logo
February 26, 2021
Kai Cheong Wong
Chief Executive Officer
AsiaFin Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail, 50250 Kuala Lumpur, Malaysia
Re:AsiaFin Holdings Corp.
Amendment No. 1 to Registration Statement on Form S-1
Filed February 8, 2021
File No. 333-251413
Dear Mr. Wong:
            We have reviewed your amended 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.  Unless we note
otherwise, our references to prior comments are to comments in our January 14, 2021 letter.
Amendment No. 1 to Registration Statement on Form S-1 filed February 8, 2021
Business Information, page 17
1.We re-issue our prior comment 2, and have the following comments based on your revised
disclosures in response to our comment:

•Please revise your Government Regulations section to discuss the effects of the
various regulations that you disclose there on your business, so that investors can
understand how the regulations are applicable to you, as well as the nature and degree
of impact of such regulations on your business.  Additionally, please consider
significantly expanding your disclosure in this section to provide a more robust
discussion of the material Hong Kong and Malaysian laws and regulations to which

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 February 26, 2021 Page 2
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
February 26, 2021
Page 2
your business is subject to including, but not limited to, acquiring necessary permits
or licenses, intellectual property rights, regulation affecting foreign-based businesses
operating in Hong Kong and Malaysia and/or tax issues.  To the extent your company
has not yet obtained all required licenses, permits or approvals, please clearly
describe the foregoing.

•As a related matter, please add risk factor disclosure addressing the risks or known
concerns relating to the regulatory environment in Hong Kong and Malaysia,
including, but not limited to, risks related to acquiring necessary permits or
licenses, the interpretation and enforcement of laws and regulations, challenges to
protecting intellectual property rights, unfavorable tax consequences for non-citizen
shareholders, restrictions on foreign investment, and the ability to transfer funds into
or out of the country.  Additionally, consider any other Hong Kong or Malaysian
laws, regulations or customs that could present material risks to your business.
•Please also add a risk factor that addresses limitations on the ability of U.S.
regulators, such as the Department of Justice, the SEC, the PCAOB and other
authorities, to conduct investigations and inspections within Hong Kong.

For additional guidance, refer to Item 101(h)(4)(viii) and (ix) of Regulation S-K, as well
as CF Disclosure Guidance: Topic No. 10.
Description of Business, page 17
2.We note your revised disclosures in response to prior comment 4, and partially re-issue
our comment.  Your revised disclosures indicate that you generated all of your revenue
from two customers for your fiscal year ended August 31, 2020, and that related party
transactions represented all your revenue during such period.  Please disclose this
information where you discuss your "present clients," including in your Prospectus
Summary, as well as your Description of Business and Results of Operations sections.
Certain Relationships and Related Transactions, page 28
3.Revise this section to include all transactions since the beginning of the last fiscal year, or
any currently proposed transaction, with related persons.  See Item 404(d) of Regulation
S-K.
Financial Statements, page F-1
4.Please update your financial statements in accordance with Rule 8-08 of Regulation S-X.

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 February 26, 2021 Page 3
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
February 26, 2021
Page 3
            You may contact Patrick Kuhn at (202) 551-3308 or Angela Lumley at (202) 551-3398 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Lamparski at (202) 551-4695 or Erin Jaskot at (202) 551-3442 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

United States securities and exchange commission logo
January 14, 2021
Kai Cheong Wong
Chief Executive Officer
AsiaFin Holdings Corp.
Suite 30.02, 30th Floor, Menara KH (Promet)
Jalan Sultan Ismail, 50250 Kuala Lumpur, Malaysia
Re:AsiaFin Holdings Corp.
Registration Statement on Form S-1
Filed December 17, 2020
File No. 333-251413
Dear Mr. Wong:
            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 S-1 filed December 17, 2020
Risk Factors, page 4
1.The description of the experience of your chief executive officer and directors on page
25 and your operations in Hong Kong and Malaysia appear to indicate that your chief
executive officer and directors are located outside of the United States.  Please include
risk factor disclosure pertaining to the difficulty that U.S. stockholders may face in
effecting service of process against your officers and directors, enforcing judgments
obtained in U.S. courts or foreign courts based on the civil liability provisions of the U.S.
federal securities laws against them, and bringing an original action in foreign courts to
enforce liabilities based on the U.S. federal securities laws against them.

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 January 14, 2021 Page 2
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
January 14, 2021
Page 2
Business Information, page 17
2.Your disclosure here provides that your subsidiary in Hong Kong functions as your
"current regional hub, carrying out the majority of [your] physical operations."  Yet
disclosure throughout the rest of your filing indicates that your "operating office [is]
in Menara KH, Malaysia" and that you have no other physical offices or operations
elsewhere.  Please revise your disclosure to reconcile these inconsistencies.
Additionally, please revise your disclosure here to describe the effect of existing or
probable government regulations upon your business as a result of your operations in
China and Malaysia.  This disclosure should cover all relevant PRC and Malaysian
regulations, including regulations relating to foreign investment as well as regulations that
are particular to the industry in which you are and will be operating.  Refer to Item
101(h)(4)(ix) of Regulation S-K.  Further, please add a risk factor that
addresses limitations on the ability of U.S. regulators, such as the Department of Justice,
the SEC, and other authorities, to conduct investigations and inspections within China.
Description of Business, page 17
3.Please substantially revise your Description of Business section as well as the disclosure
throughout your prospectus to disclose the precise status of your business with respect
to your consulting services in the “Focus Solutions” areas of “Unattended Payment
Kiosk” and “Payment Processing.”  As currently written, it is unclear whether you are
currently engaged in such operations, or whether you intend to engage in such operations
in the future.  In this regard, we note that your disclosure in the Management's Discussion
and Analysis section, prospectus cover page, and on page 1 of your Prospectus Summary
section suggests that you currently provide consultancy services in the focus area of
Unattended Payment Kiosk and Payment Processing and that you have earned revenue
from such services for the fiscal year ended August 31, 2020.  By contrast, however, your
disclosure in your Description of Business section under the sub-headings "Payment
Processing" on page 17, "Unattended Payment Kiosk" on page 18, and "Future Plans" on
page 18 suggests that you only intend to provide consulting services in these focus areas
and plan to develop your Payment Processing and Unattended Payment Kiosk focus
areas in the future.  Further, your risk factors state that you are still in the process of
developing an “effective business plan,” do not have a “definitive marketing plan to
acquire customers,” "have no arrangements in place . . . to be able to fully implement
[y]our business plan,” and, therefore, suggest that all focus areas of your business are still
in the development stage.
4.We note your disclosure on page F-10 indicating that Customer A and Customer B
accounted for 61% and 39% of your revenue, respectively, for your fiscal year ended
August 31, 2020.  Based on the disclosure in Notes 5 and 10 to the financial statements, it
appears that these customers may be related parties.  If so, please revise your disclosure
where you discuss your customers and revenues to identify such customers and clearly
state that your only customers to date are related parties.  Please also discuss the services

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 January 14, 2021 Page 3
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
January 14, 2021
Page 3
provided to such customers, so investors can understand how they relate to your current
business plan.  Please also tell us whether you have a contract with such customers for
additional services.
5.Please discuss your relationship with the vendors discussed in Note 12 to the financial
statements, including what role they play in the market research and consultancy services
provided to your customers and what you are purchasing from these vendors.  In this
regard, we note that the purchase amount from the vendor is a substantial percentage of
the revenues generated from your customers.  Please also disclose whether the vendors are
related parties or are otherwise affiliated with the company.
Selling Shareholders, page 21
6.Please revise this section to provide disclosure responsive to Item 507 of Regulation S-K,
including the nature of any material relationship which any selling security holder has had
within the past three years with you or your affiliates.  In this regard, we note that your
disclosure in the "Certain Relationships and Related Transactions" section on page 28
appears to suggest that every selling shareholder included in your selling shareholder table
on page 21 is a related person and/or entity that had or will have a material relationship
with your company.  To the extent any of your selling shareholders has
a material relationship with you or any of your affiliates, please revise the Selling
Shareholders section to reflect this.
Plan of Distribution
Procedures for Subscribing (Shares offered by us, “The Company”), page 22
7.Please clarify whether you have any plans to place any proceeds of the offering in
escrow.  In this regard, we note the disclosure on your cover page, disclosing
that proceeds of the offering from the sale of your common stock will be placed directly
into your company's "account and or the account of one of its subsidiaries."  Yet your
disclosure here and in your subscription agreement suggests that you may be using an
escrow agent in connection with this offering.  Please advise and reconcile as appropriate.
Certain Relationships and Related Transactions, page 28
8.Please ensure that you provide all information required by Item 404 of Regulation S-K for
each disclosed transaction.  In this regard, please ensure that you include the name of each
related person, disclose the basis on which the person is a related person, the related
person’s interest in the transaction, the approximate dollar value of the amount involved,
and the approximate dollar value of the amount of the related person’s interest in each
transaction.  We further note related party transactions with Insite MY Systems Sdn Bhd,
GLS IT Solutions Sdn Bhd, and SEATech Ventures (HK) Limited in Note 10 to your
financial statements that are not disclosed here.  Please revise this section to disclose these
transactions and provide the information required by Item 404.

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 January 14, 2021 Page 4
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
January 14, 2021
Page 4
Notes to Consolidated Financial Statements
Note 1. Organazation and Business Background, page F-7
9.You disclose that on December 18, 2019, you acquired 100% of the equity interests in
AsiaFIN Holdings Corp. and on December 23, 2019, AsiaFIN Holdings Corp. acquired
AsiaFIN Holdings Limited.  Regarding these acquisitions, please provide all of the
disclosures required by ASC 805-10-50.
Exhibits
10.Please have your independent registered public accounting firm correct its consent filed as
exhibit 23.1.  The consent references the registration statement on Form S-1 of AsiaFIN
Holdings Corp., Limited, but it appears that it should reference the registrant, AsiaFIN
Holdings Corp.
General
11.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) or
Rule 163B of the Securities Act, whether or not you retained, or intend to retain, copies of
those communications.  Please contact the staff member associated with the review of this
filing to discuss how to submit the materials, if any, to us for our review.
12.We note that you have nominal operations and assets (or assets consisting solely of cash
or cash equivalents).  It appears, therefore, that you are a shell company as defined under
Rule 405 of the Securities Act of 1933.  Please revise your filing, including the cover page
and Prospectus Summary, to disclose that you are a shell company as defined under the
Securities Act; please further disclose in appropriate places, including the Risk Factors
section, the consequences, challenges and risks of that status and the potential reduced
liquidity or illiquidity of your securities.  In particular, please ensure you discuss the
resale limitations of Rule 144(i) in your filing.  If you do not believe you are a shell
company, please provide us with your legal analysis in support of your belief.

 FirstName LastNameKai Cheong Wong
 Comapany NameAsiaFin Holdings Corp.
 January 14, 2021 Page 5
 FirstName LastName
Kai Cheong Wong
AsiaFin Holdings Corp.
January 14, 2021
Page 5
            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 Patrick Kuhn at (202) 551-3308 or Angela Lumley at (202) 551-3398 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Nicholas Lamparski at (202) 551-4695 or Erin Jaskot at (202) 551-3442 with any other
questions.

Sincerely,
Division of Corporation Finance
Office of Trade & Services