SecProbe.io

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 VIA EDGAR

 March 27, 2025

 Via EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Scott Stringer

 Angela Lumley

 Jenna Hough

 Dietrich King

 Re:
 Concorde International Group Ltd

 File No. 333-281799
 Registration Statement on Form F-1

 Ladies and Gentlemen:

 Pursuant to Rule 461 promulgated
under the Securities Act of 1933, as amended, Concorde International Group Ltd (the "Company") hereby requests acceleration
of effectiveness of the above referenced Registration Statement so that such Registration Statement will become effective at 4:00 p.m.
Eastern Time, on March 31, 2025, or as soon as thereafter practicable.

 Please contact Louis A. Bevilacqua
of Bevilacqua PLLC, counsel to the Company, at (202) 869-0888, ext. 100, to provide notice of effectiveness, or if you have any questions
or concerns regarding the foregoing. The Company understands that the representative of the underwriters, on behalf of the prospective
underwriters of the offering, has joined in this request in a separate letter filed with the Securities and Exchange Commission today.

 Very truly yours,

 Concorde International Group Ltd

 By:

 /s/ Swee Kheng Chua

 Name:
 Title:

 Swee Kheng Chua Chief Executive Officer and Chairman

 cc: Louis A. Bevilacqua, Esq.

CORRESP
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 VIA EDGAR

 March 27, 2025

 Via EDGAR

 United States Securities and Exchange Commission

 Division of Corporation Finance

 Office of Trade & Services

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn: Scott Stringer

 Angela Lumley

 Jenna Hough

 Dietrich King

 Re:
 Concorde International Group Ltd

 File No. 333-281799
 Registration Statement on Form F-1

 Ladies and Gentlemen:

 Pursuant to Rule 461 of the General Rules and Regulations
of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended (the "Act"), R.F. Lafferty &
Co., Inc., acting as the representative of the underwriters of the Company's initial public offering, hereby joins Concorde International
Group Ltd (the "Company") in requesting acceleration of the effective date of the above-referenced Registration Statement
(the "Registration Statement") so that it will become effective at 4:00 p.m. Eastern Time, on March 31, 2025, or as soon thereafter
as practicable, or at such other time as the Company or its counsel, Bevilacqua PLLC, may request by telephone that such Registration
Statement be declared effective.

 Pursuant to Rule 460 of the General Rules and Regulations
under the Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to participate
in the distribution of the security, as many copies of the proposed form of preliminary prospectus as appears to be reasonable to secure
adequate distribution of the preliminary prospectus.

 The undersigned advises that it has complied and will
continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

 Very truly yours,

 R.F. Lafferty & Co., Inc.

 By: /s/ Robert Hackel

 Name: Robert Hackel

 Title: Chief Operating Officer

CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

January 7, 2025

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Scott Stringer

    Angela Lumley

    Jenna Hough

    Dietrich King

    Re:
    Concorde International Group Ltd.

    Amendment No. 4 to Registration Statement on Form F-1

    Filed December 17, 2024

    File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde International
Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated January 6, 2025, providing the
Staff’s comments with respect to the Company’s Amendment No. 4 to Registration Statement on Form F-1 filed on December 17,
2024. Concurrently with the submission of this letter, the Company is submitting an Amendment No.5 to Registration Statement (the “Amendment
No.5”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 4 to Registration Statement on Form F-1

Financial Statements, page 2

    1.
    Please note the updating requirements under 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.

RESPONSE: In response to the
Staff’s comments, we have attached, as Exhibit 99.9 to Amendment No. 5, a request for a waiver of the requirements under Form 20-F,
Item 8.A.4.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

    cc:
    Louis A. Bevilacqua, Esq., Bevilacqua PLLC

January 6, 2025
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.
Amendment No. 4 to Registration Statement on Form F-1
Filed December 17, 2024
File No. 333-281799
Dear Swee Kheng Chua:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our December 10, 2024
letter.
Amendment No. 4 to Registration Statement on Form F-1
Financial Statements, page 2
1.Please note the updating requirements under 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.

January 6, 2025
Page 2
            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

CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

December 17, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Scott Stringer

    Angela Lumley

    Jenna Hough

    Dietrich King

    Re:
    Concorde International Group Ltd.

    Amendment No. 3 to Registration Statement on Form F-1

    Filed November 26, 2024

    File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde International
Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated December 10, 2024, providing the
Staff’s comments with respect to the Company’s Amendment No. 3 to Registration Statement on Form F-1 filed on November 26,
2024. Concurrently with the submission of this letter, the Company is submitting an Amendment No.4 to Registration Statement (the “Amendment
No.4”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 3 to Registration Statement on Form F-1 filed November
26, 2024

Management’s Discussion and Analysis of Financial Condition and
Results of Operations

Non-GAAP Financial Measures, page 42

    1.
    Net (Loss)/Profit for the year included in the table is calculated using adjusted amounts. Accordingly, please revise the description of this measure to present what it represents as it is confusingly similar to your measure calculated in accordance in IFRS. For instance, consider labeling the measure Adjusted Net (Loss)/Profit for the year. Refer to Question 100.05 of our Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

RESPONSE: In response to the
Staff’s comments, we respectfully advise the Staff that we have corrected the disclosure on page 42 of Amendment No.4 to reflect
adjusted net (loss)/profit in the table.

Unaudited Consolidated Financial Statements
as of and for the six months ended June 30, 2024 and 2023

Notes to Unaudited Consolidated Financial Statements

14A. Share-based Compensation, page F-75

    2.
    We note in response to our prior comment you revised your financial statements for the six month period ending June 30, 2024, to reflect total share-based compensation of $83,155,336. Please explain to us how you considered including the disclosures required by paragraph 49 of IAS 8 for the correction of an error as well as relabeling the applicable financial statement columns as restated.

RESPONSE: In response to the
Staff’s comments, we respectfully advise the Staff that we have added restatement in Note 26 on pages F-86 – F-88 and
referenced in the financial statements on pages F-42 to F-45 and F-75. Additionally, we have included the material weakness
contributing to the restatement on pages 25 and 30 of Amendment No. 4.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

    cc:
    Louis A. Bevilacqua, Esq., Bevilacqua PLLC

December 10, 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.
Amendment No. 3 to Registration Statement on Form F-1
Filed November 26, 2024
File No. 333-281799
Dear Swee Kheng Chua:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our November 19, 2024
letter.
Amendment No. 3 to Registration Statement on Form F-1 filed November 26, 2024
Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Financial Measures, page 42
1.Net (Loss)/Profit for the year included in the table is calculated using adjusted
amounts. Accordingly, please revise the description of this measure to present what it
represents as it is confusingly similar to your measure calculated in accordance in
IFRS. For instance, consider labeling the measure Adjusted Net (Loss)/Profit  for the
year. Refer to Question 100.05 of our Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures.

December 10, 2024
Page 2
Unaudited Consolidated Financial Statements as of and for the six months ended June 30,
2024 and 2023
Notes to Unaudited Consolidated Financial Statements
14A. Share-based Compensation, page F-75
2.We note in response to our prior comment you revised your financial statements for
the six month period ending June 30, 2024, to reflect total share-based compensation
of $83,155,336. Please explain to us how you considered including the disclosures
required by paragraph 49 of IAS 8 for the correction of an error as well as relabeling
the applicable financial statement columns as restated.
            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

CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

November 26, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Scott Stringer

    Angela Lumley

    Jenna Hough

    Dietrich King

    Re:
    Concorde International Group Ltd.

    Amendment No. 2 to Registration Statement on Form F-1

    Filed November 5, 2024

    File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde International
Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated November 19, 2024, providing the
Staff’s comments with respect to the Company’s Amendment No. 2 to Registration Statement on Form F-1 filed on November 5,
2024. Concurrently with the submission of this letter, the Company is submitting an Amendment No.3 to Registration Statement (the “Amendment
No.3”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each of the
Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 2 to Registration Statement on Form F-1 filed November
5, 2024

Unaudited Consolidated Financial Statements as of and for the six
months ended June 30, 2024 and 2023

Notes to Unaudited Consolidated Financial Statements

14. Equity, page F-74

    1.
    It appears from your disclosure that you issued 20,788,886 Class B Ordinary Shares to members of the Board, executive officers or their affiliates and existing shareholders, for total consideration of $208. Please tell us how you accounted for the issuance of these shares, specifically, how you determined the fair value and the reasons for any differences between those valuations of your common stock leading up to the IPO and the estimated offering price.

RESPONSE: In response to the Staff’s
comments, we respectfully advise the Staff that we have revised our financial statements for the six month period ending June 30, 2024
to reflect total share-based compensation for the 20,788,886 Class B Ordinary Shares that were issued on March 18, 2024 of $83,155,336
(the “Share Based Compensation Amount”) instead of $208. The Share Based Compensation Amount is based upon a price per share
of $4.00, which is the expected public offering price per share. The difference between the fair value and nominal value of $208 that
was paid by the recipients of the 20,788,886 Class B Ordinary Shares was recognized through the unaudited consolidated statements of profit
or loss and other comprehensive income for the six month period ended June 30, 2024 as share-based compensation. Details of this treatment
can be found on page F-75.

The Company utilized unlevered discounted
cash flow method, analyzing growth projections and benchmarking against comparable companies. The projected unlevered free cash flows
for the next five years and the terminal value, calculated in year 5 using the perpetuity growth method with an estimated 3% growth rate,
were discounted. The weighted average cost of capital (WACC) was estimated at 10.6%.

To value the Company, we applied the average
enterprise value to the Company’s last twelve months revenue (EV/LTM Revenue) multiple of 4.6x, derived from 10 comparable security
companies traded on major exchanges, with market caps ranging from $7.3 million to $3.7 billion. These peers were selected based on financial
profiles, industry, and geographic focus, with the metric chosen due to many peers being unprofitable. However, given the Company’s
profitability and growth potential, a higher multiple of 5.5x was deemed appropriate. With EV/LTM Revenue of $16.3 million, this implies
an enterprise value of $80.9 million. The Company plans to offer 1,250,000 Class A ordinary shares at $4.00 each for its initial public
offering, with 20,888,886 Class B Ordinary Shares outstanding pre-offering.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

    cc:
    Louis A. Bevilacqua, Esq., Bevilacqua PLLC

November 19, 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.
Amendment No. 2 to Registration Statement on Form F-1
Filed November 5, 2024
File No. 333-281799
Dear Swee Kheng Chua:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing
the requested information. 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 any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our October 3, 2024 letter.
Amendment No. 2 to Registration Statement on Form F-1 filed November 5, 2024
Unaudited Consolidated Financial Statements as of and for the six months ended June 30,
2024 and 2023
Notes to Unaudited Consolidated Financial Statements
14. Equity, page F-74
1.It appears from your disclosure that you issued 20,788,886 Class B Ordinary Shares to
members of the Board, executive officers or their affiliates and existing
shareholders, for total consideration of $208. Please tell us how you accounted for the
issuance of these shares, specifically, how you determined the fair value and the
reasons for any differences between those valuations of your common stock leading
up to the IPO and the estimated offering price.

November 19, 2024
Page 2
            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

CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore
569139

November 5,
2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

  Attn:
  Scott Stringer

  Angela Lumley

  Jenna Hough

  Dietrich King

  Re:
  Concorde International Group Ltd.

  Amendment No.1 to Registration Statement on Form F-1

  Filed September 18, 2024

  File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde
International Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated October 3, 2024,
providing the Staff’s comments with respect to the Company’s Amendment No. 1 to Registration Statement on Form F-1 filed on
September 18, 2024. Concurrently with the submission of this letter, the Company is submitting an Amendment No.2 to Registration Statement
(the “Amendment No.2”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each
of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Amendment No. 1 to Registration Statement on
Form F-1 filed September 18, 2024

Prospectus Summary

Singapore Subsidiary’s Loan with OCBC, page
7

1. Please clarify whether you are guaranteeing the May 28, 2024 loan secured by Concorde Security Pte
Ltd. If you are a guarantor, please file the loan documents as an exhibit to the registration statement. In addition, please disclose
the interest rate of the loan and update your liquidity disclosure on page 42 accordingly.

RESPONSE: In response to the Staff’s comments, we respectively advise the Staff
that our Chief Executive Officer, Mr. Swee Kheng Chua, his spouse, Mrs. Ping Ping Lim, and our 100% owned subsidiary Concorde international
Group Pte Ltd are the guarantors of the May 28, 2024 loan. Our British Virgin Islands holding company, Concorde International Group Ltd,
is not a guarantor of the May 28, 2024 loan. We have filed the loan document as Exhibit 10.10 to Amendment No. 2 and updated the liquidity
disclosure (with Loan 5 referring to the May 28, 2024 loan) on page 44 accordingly.

2. Please clarify whether you are guaranteeing the June 14, 2024 loan secured by Concorde Security Pte
Ltd. If you are a guarantor, please file the loan documents as an exhibit to the registration statement. In addition, please disclose
the interest rate of the loan and update your liquidity disclosure accordingly. Lastly, please disclose the key terms of the call option,
including the number of shares it covers, and file the option agreement as an exhibit to the registration statement.

RESPONSE: In response to the Staff’s comments, we respectfully advise the Staff
that our Chief Executive Officer, Mr. Swee Kheng Chua, his spouse, Mrs. Ping Ping Lim, and our 100% owned subsidiary, Concorde International
Group Pte Ltd, are the guarantors of the June 14, 2024 loan. Our British Virgin Islands holding company, Concorde International Group
Ltd, is not a guarantor of the June 14, 2024 loan. We have filed the loan document as Exhibit 10.12 to Amendment No. 2 and disclosed the
loan’s interest rate, key terms of the call options, including the number of shares it covers, on pages 7, F-41, and F-72. We have
also filed the option agreement as Exhibit 10.11 to Amendment No. 2.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua, Esq., Bevilacqua PLLC

October 3, 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.
Amendment No. 1 to Registration Statement on Form F-1
Filed September 17, 2024
File No. 333-281799
Dear Swee Kheng Chua:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our September 11, 2024 letter.
Amendment No. 1 to Registration Statement on Form F-1 filed September 18, 2024
Prospectus Summary
Singapore Subsidiary's Loan with OCBC, page 7
1.Please clarify whether you are guaranteeing the May 28, 2024 loan secured by Concorde
Security Pte Ltd. If you are a guarantor, please file the loan documents as an exhibit to the
registration statement. In addition, please disclose the interest rate of the loan and update
your liquidity disclosure on page 42 accordingly.
2.Please clarify whether you are guaranteeing the June 14, 2024 loan secured by Concorde
Security Pte Ltd. If you are a guarantor, please file the loan documents as an exhibit to the
registration statement. In addition, please disclose the interest rate of the loan and update
your liquidity disclosure accordingly. Lastly, please disclose the key terms of the call
option, including the number of shares it covers, and file the option agreement as an
exhibit to the registration statement.

October 3, 2024
Page 2
            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

CORRESP
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CONCORDE INTERNATIONAL GROUP LTD

3 Ang Mo Kio Street 62, #01-49 LINK@AMK

Singapore 569139

September 17, 2024

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Scott Stringer

    Angela Lumley

    Jenna Hough

    Dietrich King

    Re:
    Concorde International Group Ltd.

    Registration Statement on Form F-1

    Filed August 27, 2024

    File No. 333-281799

Ladies and Gentlemen:

We hereby submit the responses of Concorde
International Group Ltd. (the “Company”) to the comments of the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) set forth in the Staff’s letter, dated September 11, 2024,
providing the Staff’s comments with respect to the Company’s Registration Statement on Form F-1 filed on August 27, 2024.
Concurrently with the submission of this letter, the Company is submitting an Amendment No.1 to Registration Statement (the “Amendment
No.1”) on Form F-1 via EDGAR with the Commission.

For the convenience of the Staff, each
of the Staff’s comments is included and is followed by the corresponding response of the Company. Unless the context indicates otherwise,
references in this letter to “we,” “us” and “our” refer to the Company on a consolidated basis.

Registration Statement on Form F-1 filed August 27, 2024

Use of Proceeds, page 32

 1. We note your disclosure of how you plan to use the net proceeds totaling $5,000,000
appears to be inconsistent with your disclosure of the expected net proceeds of $4,400,000. Please clarify or revise.

RESPONSE:
In response to the Staff’s comments, we have revised the Use of Proceeds section on page 32.

Dilution, page 35

 2. The dilution amount of $4.20 in net tangible book value to new investors in the
offering appears to be inconsistent with the initial public offering price less the pro forma net tangible book value per share. Please
clarify or revise.

RESPONSE:
In response to the Staff’s comments, we have revised the dilution amount to $3.68 and updated the related disclosure on page
35.

If you would like to discuss any of the responses
to the Staff’s comments or if you would like to discuss any other matters, please contact the undersigned at +65 2960802 or Louis
A. Bevilacqua of Bevilacqua PLLC at (202) 869-0888 (ext. 100).

    Sincerely,

    Concorde International Group Ltd.

    By:
    /s/ Swee Kheng Chua

    Name:
    Swee Kheng Chua

    Title:
    Chief Executive Officer

cc: Louis A. Bevilacqua, Esq., Bevilacqua PLLC

September 11, 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.
Registration Statement on Form F-1
Filed August 27, 2024
File No. 333-281799
Dear Swee Kheng Chua:
            We have reviewed your amended registration statement and have the following
comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our July 10, 2024 letter.
Registration Statement on Form F-1 filed August 27, 2024
Use of Proceeds, page 32
1.We note your disclosure of how you plan to use the net proceeds totaling $5,000,000
appears to be inconsistent with your disclosure of the expected net proceeds of
$4,400,000. Please clarify or revise.
Dilution, page 35
2.The dilution amount of $4.20 in net tangible book value to new investors in the offering
appears to be inconsistent with the initial public offering price less the pro forma net
tangible book value per share. Please clarify or revise.

September 11, 2024
Page 2
            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

July 10, 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.
Amendment No.1 to Draft Registration Statement on Form F-1
Submitted June 27, 2024
CIK No. 0002001794
Dear Swee Kheng Chua:
            We have reviewed your amended 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. Unless we note otherwise, any references to prior comments are to comments in our
April 16, 2024 letter.
Amendment No.1 to Draft Registration Statement on Form F-1 submitted June 27, 2024
Capitalization, page 36
1.Please revise to include indebtedness in your capitalization. Refer to Item 3B of Form 20-
F.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 43
We note revenue from I-Guarding Services increased 111% and accounted for 98% of
total revenue in 2023. Disclosure indicates "the increase was primarily due to growth in
clientele and secured new contracts with customers." Please tell us how you measure
growth in clientele and what key performance indicators or key variables management 2.

July 10, 2024
Page 2
uses to monitor your ability to grow and attract new customers. Additionally, please
explain your consideration of including a quantified discussion of such measures to
provide context and enhance a readers understanding. We refer you to SEC Release 33-
10751.
3.Please quantify factors primarily responsible for changes. When a change is attributable to
more than one factor, please quantify each material component. For example, we note
your discussion of other income, employee benefits expenses, and distribution
expenses identifies underlying factors, often more than one, that caused changes in the
various line items without quantification. Refer to Item 5 of Form 20-F and SEC Release
No. 33-8350.
4.We refer you to your discussion of costs and expenses, in particular "Others" on page 45.
Please explain the nature of the "unrealized exchanged loss" and how it relates to the
increase in license fee.
Liquidity and Capital Resources, page 45
5.We note your response to comment 8 and reissue it in full. As previously requested,
please discuss in the liquidity section the debt summarized in footnote 10 to the financial
statements.
Related Party Transactions, page 78
6.We note your response to comment 9 and reissue in full. As previously requested, please
provide all of the information required by Item 404 of Regulation S-K. We particularly
note the requirements of Item 404(a)(1) and Item 404(a)(2).
Description of Share Capital, page 79
7.We note your revised disclosure pursuant to comment 1 and reissue in part. Please revise
your Description of Share Capital section to disclose 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, and
provide cross references to applicable risk factors.
Report of Independent Registered Accounting Firm, page F-2
8.We note the disclosure on page 5 which states that your independent registered public
accounting firm expressed substantial doubt regarding your ability to continue as a going
concern.  This appears to be inconsistent with audit opinion issued by your independent
registered public accounting firm.  Please clarify or revise.
3. Significant accounting policies
3.4 Revenue recognition,, page F-11
We note your revised disclosure in response to prior comment 11 noting it does not
appear to address our comment, therefore it is being reissued. We note your disclosure in
(b) that I-Guarding (including, installation and maintenance services) still appears to give
prominence to and indicate a majority of your I-Guarding Services are recognized at a
point in time. This disclosure appears to be inconsistent with the table that presents
"timing of transfer of goods or services" on page F-31 which states that a majority of the 9.

July 10, 2024
Page 3
revenue is recognized over time. Please clarify or revise. In addition, we note per the
disclosure on page 63 that 96% 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, is in accordance with IFRS 9
paragraphs 35–37.
Notes to the Consolidated Financial Statements
14. Earnings/(Loss) per share, page F-31
10.We note your calculation of earning per share is based on weighted average number of
100,000 shares outstanding. This appears to be inconsistent with the disclosure in Note 13
on page F-30 which shows one share issued and outstanding and the The
Offering summary on page 10 which indicates the ordinary shares outstanding
immediately before the offering are zero Class A shares and 20,888,886 Class B shares.
Please explain the number of shares issued and outstanding as of the balance sheet date
and tell us how you a calculated the weighted average shares outstanding for earnings per
share.
            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

United States securities and exchange commission logo
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