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                               February 20, 2024

       Mark Cloutier
       Chief Executive Officer
       Aspen Insurance Holdings Limited
       141 Front Street
       Hamilton, HM19
       Bermuda

                                                        Re: Aspen Insurance
Holdings Limited
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed February 1,
2024
                                                            File No. 333-276163

       Dear Mark Cloutier:

            We have reviewed your amended registration statement and have the
following
       comments.

              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 January 12, 2024
letter.

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

       General

   1.                                                   We note your response
to prior comment 4 and reissue. Because CAGR only represents
                                                        two discrete snapshots
in time but does not show trends or events during the periods
                                                        represented, please
balance your disclosure by also including the annual rates for the
                                                        periods represented and
indicate that such growth trends may not continue.
       Risk Factors, page 28

   2.                                                   We note your response
to prior comment 3. Please add a separately captioned risk factor
                                                        describing your
multiple class share structure, the disparate voting rights, and the risks the
                                                        structure presents to
investors.
 Mark Cloutier
FirstName LastNameMark   Cloutier
Aspen Insurance Holdings Limited
Comapany20,
February  NameAspen
            2024      Insurance Holdings Limited
February
Page 2 20, 2024 Page 2
FirstName LastName
Management's Discussion and Analysis, page 82

3.       We note your response to prior comment 7 and the revised disclosure on
page 83
         addressing macro effects of inflation. We note the discussion on page
31 regarding the
         current hard market cycle, which you indicate has been supported
partly by inflation. We
         also note discussions on pages 34 and 35 regarding inflation and
related economic factors
         potentially impacting, for example, reserves, the debt securities
portfolio and policy
         holder loss costs. However, we are unable to locate revised disclosure
in Management's
         Discussion and Analysis other than the macro effects on page 83.
Please revise the period-
         to-period analyses to address the extent to which inflation and
related economic factors
         have materially impacted your financial condition, changes in
financial condition and
         results of operations.
Conflicts Committee, page 179

4.       We note your response to prior comment 12. We also note Apollo's
operations and
         interests in other entities engaged in insurance. Given Apollo's
control as described on
         page 23, please revise to address potential conflicts of interest and
include risk factor
         disclosure as appropriate.
Executive Compensation
Summary of Compensation, page 201

5.       Please update your executive compensation disclosure for the 2023
fiscal year. Refer to
         Item 6.B. of Form 20-F.
Principal and Selling Shareholders, page 202

6.       We note your footnote (1) to the beneficial ownership table on page
203. Please disclose
         the natural person or persons who have voting and dipositive control
over the shares held
         by Highlands Bermuda Holdco, Ltd.
Exclusive Jurisdiction, page 215

7.       We note your response to prior comment 13 and reissue. Your revised
disclosure on pages
         62 and 215 appears to indicate that the exclusive jurisdiction
provision does not apply to
         actions arising under the Securities Act or Exchange Act. If so,
please revise to state this
         clearly here and on page 62. In addition, ensure that the exclusive
forum provision in the
         governing documents also states this clearly, or tell us how you will
inform investors in
         future filings that the provision does not apply to any actions
arising under the Securities
         Act or Exchange Act.
 Mark Cloutier
Aspen Insurance Holdings Limited
February 20, 2024
Page 3

       Please contact Tonya Aldave at 202-551-3601 or James Lopez at
202-551-3536 with any
other questions.



                                                        Sincerely,
FirstName LastNameMark Cloutier
                                                        Division of Corporation
Finance
Comapany NameAspen Insurance Holdings Limited
                                                        Office of Finance
February 20, 2024 Page 3
cc:       Robert A. Ryan, Esq.
FirstName LastName