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                            August 26, 2022

       Orla Gregory
       Chief Financial Officer
       Enstar Group Limited
       Windsor Place, 3rd Floor
       22 Queen Street
       Hamilton HM JX, Bermuda

                                                        Re: Enstar Group
Limited
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2021
                                                            Filed February 24,
2022
                                                            File No. 001-33289

       Dear Ms. Gregory:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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-K filed February 24, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 63

   1.                                                   We note your
disclosures regarding Non-GAAP Financial Measures included on pages
                                                        63-70, and related
discussions of those measures throughout the filing. Given the
                                                        extensive amount of
disclosure associated with these measures, please tell us how you
                                                        considered whether your
disclosures and presentation cause these non-GAAP measures to
                                                        be more prominent than
the most directly comparable GAAP measures. Refer to Item
                                                        10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the Compliance and Disclosure
                                                        Interpretations on
Non-GAAP Financial Measures.
   2.                                                   We note your
explanation of the purpose for the various non-GAAP measures and
                                                        adjustments on pages
63-65 appears to be generic and non-specific to each individual
 Orla Gregory
Enstar Group Limited
August 26, 2022
Page 2
         adjustment. Please tell us and consider the need to revise your
disclosures, in future
         filings, to provide a clearer explanation of each individual
adjustment and the Company's
         basis for exclusion.
3.       In addition to the information requested in the comment above, it
appears that the
         Company's basis for excluding many of the adjustments are that they
are not considered
         indicative of the Company's ongoing operations. For example, such
items appear to
         include provisions for unallocated LAE, reduction in estimates of net
ultimate losses -
         current period, changes in fair value - fair value option, net gain on
purchase and sale of
         subsidiaries, legacy underwriting and Enhanzed Re operations and
changes in A&E
         liabilities. In the context of each non-GAAP financial measure
presented and considering
         the nature and significance of the activities to the Company's
operations, please explain to
         us your basis for asserting that such adjustments and items are not
recurring, normal
         activities that are part of the Company's ongoing operations.
4.       We note that some of the non-GAAP adjustments appear to be changing
the basis of
         accounting applied under U.S. GAAP. For example, such items appear to
include the
         exclusion of the change in fair value of insurance contracts (i.e.,
discount rate and risk
         margin components) for which you have elected the fair value option
and changes in the
         classification of investable assets based on a management view that
looks through    the
         legal form of an investment. In the context of each non-GAAP financial
measure
         presented, please tell us how you considered whether these adjustments
substitute
         individually tailored recognition and measurement methods, which could
lead in a
         misleading measure that violates Rule 100(b) of Regulation G. Refer to
Question 100.04
         of the Compliance and Disclosure Interpretations on Non-GAAP Financial
Measures.
       In closing, 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 Lory Empie, Staff Accountant, at 202-551-3714 or Robert
Klein,
Accounting Branch Chief, at 202-551-3847 with any questions.



FirstName LastNameOrla Gregory                                 Sincerely,
Comapany NameEnstar Group Limited
                                                               Division of
Corporation Finance
August 26, 2022 Page 2                                         Office of
Finance
FirstName LastName