SecProbe.io

CORRESP
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 Uni-Fuels
Holdings Ltd

 15
Beach Road, Beach Centre #05-07

 Singapore
189677

 +65
6027 1250

 February
4, 2026

 VIA
EDGAR

 Attention:
Rebekah Reed

 Securities
and Exchange Commission

 100
F Street, N.E.

 Washington,
D.C. 20549

 RE :

 Uni-Fuels
 Holdings Ltd (the "Company")

 Registration
 File No. 333-292786

 (the
 "Registration Statement")

 Request
 for Acceleration of Effective Date

 Ladies
and Gentleman:

 In
accordance with Rule 461 under the Securities Act of 1933, as amended (the "Act"), the Company requests that the Securities
and Exchange Commission (the "Commission") take appropriate action to cause the Registration Statement on Form F-3 to be
declared effective on February 6, 2026 at 5:00 p.m., Eastern Time, or as soon as practicable thereafter.

 Very
 truly yours,

 Uni-Fuels
 Holdings Ltd

 By:

 /s/
 Koh Kuan Hua

 Name:
 Koh
 Kuan Hua

 Title:
 Chief
 Executive Officer and Director

 cc:
 Lawrence
 Venick, Esq.

 Loeb
 & Loeb LLP

January 22, 2026
Koh Kuan Hua
Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677
Re:Uni-Fuels Holdings Ltd
Registration Statement on Form F-3
Filed January 16, 2026
File No. 333-292786
Dear Koh Kuan Hua:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Rebekah Reed at 202-551-5332 with any questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services

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 Uni-Fuels
Holdings Limited

 15
Beach Road, Beach Centre #05-07

 Singapore
189677

 +65
6027 1250

 March
20, 2025

 VIA
EDGAR & TELECOPY

 Attn:
Kate Beukenkamp

 Division
of Corporation Finance

 Office
of Trade & Services

 U.S.
Securities & Exchange Commission

 100
F Street, NE

 Washington,
D.C. 20549

 RE:
 Uni-Fuels
 Holdings Limited (the "Company")

 Registration
 Statement on Form F-1

 (File
 No. 333-285874) (the "Registration Statement")

 Dear
Ms. Beukenkamp:

 The
Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness
of the Registration Statement so that such Registration Statement will become effective as of 5:00 p.m. on March 24, 2025, or as soon
thereafter as practicable.

 The
Company hereby acknowledges that:

 ●
 Should
 the Securities and Exchange Commission (the "Commission") or the Staff, acting pursuant to delegated authority, declare
 the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
 Statement;

 ●
 The
 action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective,
 does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement;
 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.

 If
there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the
Company may be making an oral request of acceleration of the effectiveness of the Registration Statements in accordance with Rule 461
of Regulation C. Such request may be made by an executive officer of the Company or by any attorney from the Company's U.S. counsel,
Loeb & Loeb LLP.

 [Signature
page follows]

 Very
 truly yours,

 Uni-Fuels
 Holdings Limited

 By:
 /s/
 Koh Kuan Hua

 Name:
 Koh
 Kuan Hua

 Title:
 Chief
 Executive Officer

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 March 13, 2025

Koh Kuan Hua
Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677

 Re: Uni-Fuels Holdings Ltd
 Draft Registration Statement on Form F-1
 Submitted March 7, 2025
 CIK No. 0002021688
Dear Koh Kuan Hua:

 This is to advise you that we do not intend to review your registration
statement.

 We request that you publicly file your registration statement no later
than 48 hours
prior to the requested effective date and time. Please refer to Rules 460 and
461 regarding
requests for acceleration. 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 Kate Beukenkamp at 202-551-3861 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
cc: Lawrence S. Venick
</TEXT>
</DOCUMENT>

CORRESP
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UNI-FUELS
HOLDINGS LIMITED

VIA
EDGAR

January
7, 2025

U.S.
Securities & Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

Washington,
D.C. 20549

Attn:
Kate Beukenkamp and Donald Field

    Re:
    Uni-Fuels
    Holdings Limited

    Registration
    Statement on Form F-1

    Filed
    December 27, 2024, as amended

    File
    No. 333-282849

Pursuant
to Rule 461 under the Securities Act of 1933, as amended, Uni-Fuels Holdings Limited hereby requests acceleration of effectiveness of
the above referenced Registration Statement so that it will become effective at 4:00 pm, Eastern Time, on January 10, 2025, or as soon
as thereafter practicable.

    Very
    truly yours,

    /s/
    Koh Kuan Hua

    Koh
    Kuan Hua

    Chief
    Executive Officer and Director

    cc:
    Loeb
    & Loeb LLP

    Ellenoff
    Grossman & Schole LLP

CORRESP
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R.F.
Lafferty & Co., Inc.

40
Wal Street, 27th Floor

New
York, NY 10005

January
7, 2025

VIA
EDGAR

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Kate Beukenkamp

    Re:

    Uni-Fuels
    Holdings Limited

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

    Submitted
    December 27, 2024

    File
    No. 333-282849

Dear
Ms. Beukenkamp,

Pursuant
to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned,
which is acting as the representative of the underwriters of the offering, hereby joins in the request of Uni-Fuels Holdings Limited
that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00
p.m., Eastern Time, on January 10, 2025, or as soon as thereafter practicable.

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 the requirements of Rule 15c2-8 under the Securities Exchange
Act of 1934, as amended.

[Signature
page follows]

    Very
    truly yours,

    R.F.
    Lafferty & Co., Inc.

    By:
    /s/
    Robert Hackel

    Name:

    Robert
    Hackel

    Title:

    Chief
    Operating Officer

CORRESP
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October
25, 2024

Via
EDGAR

Ms.
Kate Beukenkamp / Mr. Donald Field

U.S.
Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

Washington,
D.C. 20549

    Re:
    Uni-Fuels
    Holdings Ltd (the “Company”)

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

    Submitted
    October 3, 2024

    CIK
    No. 0002021688

Dear
Ms. Beukenkamp / Mr. Field

As
counsel for the Company and on its behalf, this letter is being submitted in response to the letter dated June 18, 2024 from the U.S.
Securities and Exchange Commission (the “Commission”) in which the staff of the Commission (the “Staff”)
commented on the above-referenced Draft Registration Statement on Form F-1. Contemporaneously, we are publicly filing the Registration
Statement via Edgar (the “Registration Statement”).

For
the Staff’s convenience, the Staff’s comment has been stated below in its entirety, with the Company’s response set
out immediately underneath such comment.

Amendment
No. 2 to Draft Registration Statement on Form F-1 submitted October 3, 2024

Prospectus
Summary

Our
Corporate Structure and History, page 5

    1.
    We
    note the revisions to your corporate structure diagrams to include the minority shareholders. Please revise the diagram and elsewhere
    throughout your registration statement as appropriate to reflect the names of the five minority shareholders and disclose whether
    they are related parties, as applicable. If helpful, consider the use of footnotes.

Response:
The Company has revised the disclosures on pages 5, 6, 55 and 56 of the Registration Statement to revise footnote to the corporate
structure diagrams to include the names of the five minority shareholders and disclose that none of these minority shareholders if a
related party.

Capitalization,
page 37

    2.
    Please
    tell us your consideration of including debt in your calculation of total capitalization. Refer to Item 3.B. of Form 20-F.

Response:
In consideration of the Staff’s comment and pursuant to the requirements set out under Item 3.B. of Form 20-F, the Company
has revised the disclosure on page 37 of the Registration Statement to include debt in the calculation of total capitalization.

Principal
Shareholders, page 86

    3.
    Please
    note that beneficial ownership information is to be provided for each beneficial owner of 5% or more of each class of the company’s
    voting securities. In this regard, we note that you have five minority shareholders who appear to collectively own (in equal amounts)
    all of your outstanding Class A Ordinary Shares. Please revise to include the required information for these major shareholders.
    Refer to Item 7.A.1 of Form 20-F.

Response:
The Company has revised the disclosures on page 86 of the Registration Statement to include information of the five shareholders
of Class A Ordinary Shares.

Consolidated
Financial Statements for the Years Ended December 31, 2023 and 2022

Notes
to Consolidated Financial Statements

9.
Shareholders’ Equity

Ordinary
shares, page F-17

    4.
    We
    note from your disclosure on September 3, 2024, 29,999,999 shares of Class B shares with a par value of $0.0001 were issued. Please
    tell us your basis for accounting for the issuance of these shares on a retrospective basis. In addition, please tell us your consideration
    of ASC 505-20.

Response:
The Company has revised the disclosure on pages F-17 and F-37 of the Registration Statement in accordance with the Staff’s
comment. The Company respectfully advises the Staff that the allotment of 29,999,999 Class B ordinary shares was part of its recapitalization
prior to the completion of its initial public offering (the “IPO”). This allotment was solely intended to increase the number
of shares and represented an adjustment to the Company’s share structure, aimed at realigning its capital structure to facilitate
the subsequent issuance of new shares for the IPO. The shares were issued at par value, with no consideration paid. Therefore, the Company
considers the allotment of 29,999,999 Class B ordinary shares to be a share split.

Under
ASC 260-10-55-12, when there is an increase in the number of ordinary shares as a result of a stock split, the calculations of basic
and diluted earnings per share (EPS) should be adjusted retroactively for all periods presented. If such a change occurs after the close
of the period but before the financial statements are issued or made available, the per-share computations for those and any prior-period
financial statements presented must be based on the new number of shares.

Additionally,
in accordance with ASC 505-20, the guidance for stock splits allows for retrospective adjustments to the number of shares outstanding
to present a consistent historical record. Thus, the allotment should be reflected as if it had occurred at the beginning of the earliest
period presented, ensuring the comparability and consistency of the financial statements. Further in accordance with SAB Topic 4C, such
change to capital structure shall also be given retroactive effect in the balance sheet.

Therefore,
the Company believes it is appropriate to reflect the transaction on a retroactive basis. All share and per-share amounts have been retroactively
restated in compliance with the relevant guidance under ASC 260-10-55-12, ASC 505-20 and SAB Topic 4C.

Please
contact the undersigned at (852) 3923-1188 if you have any questions with respect to the responses contained in this letter.

Sincerely,

    /s/
    Lawrence S. Venick

    Lawrence
    S. Venick

    Direct
    Dial: +852.3923.1188

    Email:
    lvenick@loeb.com

October 18, 2024
Koh Kuan Hua
Chairman and Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677
Re:Uni-Fuels Holdings Ltd
Amendment No. 2 to Draft Registration Statement on Form F-1
Submitted October 3, 2024
CIK No. 0002021688
Dear Koh Kuan Hua:
            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 June 18, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1 submitted October 3, 2024
Prospectus Summary
Our Corporate Structure and History, page 5
1.We note the revisions to your corporate structure diagrams to include the minority
shareholders. Please revise the diagram and elsewhere throughout your registration
statement as appropriate to reflect the names of the five minority shareholders and
disclose whether they are related parties, as applicable. If helpful, consider the use of
footnotes.

October 18, 2024
Page 2
Capitalization, page 37
2.Please tell us your consideration of including debt in your calculation of total
capitalization. Refer to Item 3.B. of Form 20-F.
Principal Shareholders, page 86
3.Please note that beneficial ownership information is to be provided for each beneficial
owner of 5% or more of each class  of the company’s voting securities. In this regard,
we note that you have five minority shareholders who appear to collectively own (in
equal amounts) all of your outstanding Class A Ordinary Shares. Please revise to
include the required information for these major shareholders. Refer to Item 7.A.1 of
Form 20-F.
Consolidated Financial Statements for the Years Ended December 31, 2023 and 2022
Notes to Consolidated Financial Statements
9. Shareholders' Equity
Ordinary shares, page F-17
4.We note from your disclosure on September 3, 2024, 29,999,999 shares of Class B
shares with a par value of $0.0001 were issued. Please tell us your basis for
accounting for the issuance of these shares on a retrospective basis. In addition, please
tell us your consideration of ASC 505-20.
            Please contact Tony Watson at 202-551-3318 or Angela Lumley at 202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680
with any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:Lawrence S. Venick

United States securities and exchange commission logo
June 18, 2024
Koh Kuan Hua
Chairman and Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677
Re:Uni-Fuels Holdings Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted June 6, 2024
CIK No. 0002021688
Dear Koh Kuan Hua:
            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
May 31, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form F-1 submitted June 6, 2024
Business
Our Major Customers, page 67
1.We note your response to prior comment 12 and reissue in part. Please revise to disclose
the names of the customers to which the company's business and profitability is
dependent. Further, please disclose whether any of the customers referenced in this
section are related parties. Refer to Item 4.B.6 of Part I of Form 20-F.

 FirstName LastNameKoh Kuan Hua
 Comapany NameUni-Fuels Holdings Ltd
 June 18, 2024 Page 2
 FirstName LastName
Koh Kuan Hua
Uni-Fuels Holdings Ltd
June 18, 2024
Page 2
            Please contact Tony Watson at 202-551-3318 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lawrence S. Venick

United States securities and exchange commission logo
May 31, 2024
Koh Kuan Hua
Chairman and Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677
Re:Uni-Fuels Holdings Ltd
Draft Registration Statement on Form F-1
Submitted May 3, 2024
CIK No. 0002021688
Dear Koh Kuan Hua:
            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 May 3, 2024
Cover Page
1.Please revise your cover page and elsewhere as appropriate, including your section titled
"Implications of Being a Controlled Company," to make clear whether you intend to
utilize the exemptions available under the Nasdaq listing standards related to the
expectation that you will be a "controlled company." We note your risk factor beginning
"[w]e will be a "controlled company" within the meaning of the Nasdaq Stock Market
listing rules..." on page 32, including disclosure stating that you "do not currently plan to
utilize the exemptions available for controlled companies..." as well as the risk factor
immediately above beginning "[w]e do not expect to be subject to certain Nasdaq
corporate governance rule..." discussing your intention to voluntarily adopt certain
corporate governance rules applicable to U.S. listed companies.
2.Please revise your cover page, Prospectus Summary and Capitalization sections to
describe your capital structure, including the different authorized classes of ordinary

 FirstName LastNameKoh Kuan Hua
 Comapany NameUni-Fuels Holdings Ltd
 May 31, 2024 Page 2
 FirstName LastName
Koh Kuan Hua
Uni-Fuels Holdings Ltd
May 31, 2024
Page 2
shares and any disparate voting rights. We note your disclosure elsewhere, including in
your risk factor beginning "[t]he dual-class structure of our Ordinary Shares has the effect
of concentrating voting control..." on page 24 discussing your dual-class share structure of
Class A and Class B Ordinary Shares and the respective votes per share of each class.
3.Please refer to the third paragraph and the risk factor cross-reference. Please revise to also
include the page number of where the section appears in the prospectus. Refer to Item
501(b)(5) of Regulation S-K.
Prospectus Summary
Our Corporate Structure and History, page 5
4.Please revise both your pre- and post-offering ownership diagrams to reflect the holdings
of Koh Kuan Hua, your Chief Executive Officer, in Garden City Private Capital Limited,
an entity wholly-owned by him. Additionally, please revise these diagrams to reflect the
respective pre- and post-offering ownership and voting control held by these parties as
well as the Public shareholders, respectively. In this regard, we note disclosure related to
your Class B Ordinary Shares and the ten-to-one voting ratio between your Class B and
Class A Ordinary Shares.
Conventions Which Apply to this Prospectus, page 8
5.Please revise your disclosure throughout this registration statement to accurately and
consistently reference your "major shareholders." Consider using the defined term "Major
Shareholder(s)" defined here and used as appropriate. Additionally, please revise this
section to clarify the statement that Garden City Private Capital Limited, an entity wholly-
owned by your CEO, Mr, Hua, is "his personal holding company."
Lock-up, page 10
6.Please revise to clarify whether Mr. Hua, your major shareholder, is subject to the
referenced lock-up.
Risk Factors
Risks Related to Our Business
We are exposed to concentration of credit risk with respect to accounting receivable., page 15
7.Please revise this section to disclose whether you have subsequently successfully collected
the accounts receivable for the fiscal year ended December 31, 2022. Additionally, please
disclose whether the single customer representing receivables accounting for 10% or more
of your total balances of accounts receivable was also one of the two customers that
accounted for a significant portion of the Group's total balances of accounts receivable in
the fiscal year ending December 31, 2022. Last, please disclose whether these customers
are related parties.

 FirstName LastNameKoh Kuan Hua
 Comapany NameUni-Fuels Holdings Ltd
 May 31, 2024 Page 3
 FirstName LastName
Koh Kuan Hua
Uni-Fuels Holdings Ltd
May 31, 2024
Page 3
We source marine fuels from a limited number of third-party vendors..., page 15
8.We note your disclosure regarding the risk associated with the loss of any of your marine
fuels third-party vendors and its negative impact on your business related to these "supply
arrangements." Please revise your disclosure here and elsewhere as appropriate to discuss
whether you enter into written agreements with these third-party vendors as well as your
customers. If so, please described the material terms of these agreements and file any
material written agreements in compliance with Item 601(b)(10) of Regulation S-K.
Any damage to the reputation and recognition of our brand names..., page 17
9.Please revise this risk factor and elsewhere as appropriate, including your Business
section, to disclose and briefly discuss your brand and brand names referenced here. In
this regard, we note that your Business section does not emphasize the significance of
your brand and the "Intellectual Property" section of this registration statement states that
you have "limited exposure to intellectual property risk." However, we do note your
application filed to register your Uni-Fuels trademark.
Management's Discussion and Analysis...
Liquidity and Capital Resources, page 46
10.We note your discussion here that your principal sources of liquidity include "from the
financing provided by a financing institution." Additionally, in your Risk Factor section,
including the risk factor beginning "[o]ur business is dependent on our ability to obtain
financing..." on page 15, you discuss your "trade financing facility from a financial
institution" and that you plan to increase your trade financing facility with financial
institutions. Please revise your disclosure here, in your Risk Factors section and elsewhere
as appropriate to briefly discuss your trade financing facility in greater detail, including
the key terms of this facility and the financial institution(s) involved. Additionally, please
file this facility as an exhibit. Refer to Item 601(b)(10) of Regulation S-K.
11.Please expand your disclosure to briefly describe the nature and amount of the principal
source of liquidity to finance your day-to-day operations received from your major
shareholder. We note your disclosure in the section titled "Related Party Transactions" on
page 84.
Business
Our Major Customers, page 67
12.Please revise to disclose the names of your four major customers that accounted for 10%
or more of the Group's revenues for the year ended December 31, 2022.
Related Party Transactions, page 84
13.Please revise this section, including footnotes as appropriate, to clarify the nature of the
related party relationship with Sea Oil Petroleum. We note your disclosure in the table

 FirstName LastNameKoh Kuan Hua
 Comapany NameUni-Fuels Holdings Ltd
 May 31, 2024 Page 4
 FirstName LastName
Koh Kuan Hua
Uni-Fuels Holdings Ltd
May 31, 2024
Page 4
titled "Nature of relationships with related parties" describing the company's relationship
with Sea Oil Petroleum as "[u]nder significant influence of Koh Kuan Hua..."
General
14.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 the staff member associated with the review of this filing
to discuss how to submit the materials, if any, to us for our review.
            Please contact Tony Watson at 202-551-3318 or Angela Lumley at 202-551-3398 if you
have questions regarding comments on the financial statements and related matters. Please
contact Kate Beukenkamp at 202-551-3861 or Donald Field at 202-551-3680 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       Lawrence S. Venick