February 12, 2020

Johan Kroner
Senior Vice President and Chief Financial Officer
Universal Corporation
9201 Forest Hill Avenue
Richmond, Virginia 23235

       Re: Universal Corporation
           Form 10-K for Fiscal Year Ended March 31, 2019
           Form 10-Q for Fiscal Quarter Ended December 31, 2019
           Form 8-K filed February 4, 2020
           File No. 001-00652

Dear Mr. Kroner:

      We have reviewed your filings and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-Q for Fiscal Quarter Ended December 31, 2019

Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Other Items, page 32

1.    You present Adjusted operating income, Adjusted net income available to
Universal
      Corporation, and Adjusted diluted earnings per share for the three months
and nine
      months ended December 31, 2019 and 2018. These measures appear to be
non-GAAP
      financial measures. Please tell us how you considered the disclosure
requirements in Item
      10(e)(1)(i)(C) and (D) of Regulation S-K. Please note that this comment
also applies to
      your press release filed under Item 2.02 of Form 8-K dated February 4,
2020.
        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.
 Johan Kroner
Universal Corporation
February 12, 2020
Page 2

       You may contact Blaise Rhodes at 202-551-3774 or Suying Li at
202-551-3335 if you
have any questions.



FirstName LastNameJohan Kroner                          Sincerely,
Comapany NameUniversal Corporation
                                                        Division of Corporation
Finance
February 12, 2020 Page 2                                Office of Trade &
Services
FirstName LastName