May 14, 2019

Mark Jensen
Chief Executive Officer
American Resources Corp
9002 Technology Drive
Fishers, Indiana 46038

       Re: American Resources Corp.
           Form 10-K for the Year Ended December 31, 2018
           Filed April 3, 2019
           Form 8-K as of February 12, 2019
           Filed February 22, 2019
           File No. 001-38816

Dear Mr. Jensen:

       We have reviewed your filing 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 for the Year Ended December 31, 2018

Results of Operations for the years ended December 31, 2018 and December 31,
2017, page 34

1.    We note the 51% increase in revenues for 2018 compared to 2017 and your
disclosure on
      pages 5-9 regarding coal sales from certain mines of McCoy, Knott Country
Coal, Deane
      Mining LLC. To facilitate your investors' assessment of your operating
results, please
      provide a narrative discussion quantifying the extent to which your
revenue growth
      is attributable to increases in coal prices or volume and amount/ nature
of any coal-related
      services sold. Please provide a comparison of the aggregate tons of coal
sold and average
      realized prices per ton sold for the periods presented. If material,
please disaggregate
      other service revenues. Refer to Item 303(a)(3)(iii) of Regulation S-K.
 Mark Jensen
FirstNameResources Corp Jensen
American LastNameMark
Comapany NameAmerican Resources Corp
May 14, 2019
May 14, 2019 Page 2
Page 2
FirstName LastName
Consolidated Statements of Cash Flows, page F-6

2.       We note the significant increase in mine development costs as reported
in your balance
         sheet. Please disclose how you paid for such costs and clarify how
they are reflected in the
         Consolidated Statements of Cash Flows.
3.       Tell us your basis for concluding that your liability for accrued
management fee has been
         extinguished. Refer to 405-20-40. In addition, please include a note
in the financial
         statements to disclose the settlement terms for the forgiveness of the
management fee as
         reported under supplemental information hereunder.
Note 9 - Correction of Prior Year Information, page F-25

4.       Please indicate on the face of your balance sheet, income statement,
and statement of cash
         flows that the amounts reported in the 2017 columns have been
restated.
Form 8-K filed February 22, 2019

Item 2.01 Completion of Acquisition or Disposition of Assets, page 2

5.       Refer to Exhibits 99.1 and 99.2. We note that you entered into an
Asset Purchase
         Agreement and Agreement and Plan of Merger dated as of February 20,
2019, with
         retroactive effectiveness as of February 1, 2019 and February 12,
2019, respectively. It
         appears that the consideration for the asset acquisition was in the
form of $500,000 in cash
         and a $2 million promissory note. Additionally, in connection with the
Merger
         Agreement, the seller (Empire) was also given a right to receive 2
million shares of your
         stock prior to the effective time pursuant to a fixed exchange ratio
to the seller's
         outstanding shares. Tell us your basis for determining the fair value
of such rights and the
         deemed grant date for measurement purposes. Please refer to your basis
in the accounting
         literature. In your response, please address the reasons for the
significant lead time
         between the effective date(s) and closing date of the related
transactions, and satisfaction
         of certain closing conditions such as receipt of shareholder approval,
the NASDAQ
         listing, Form S-4 effectiveness, and third party consents (among
others referenced in
         Section 6 of the Merger Agreement).
        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 Kathryn Jacobson, Senior Staff Accountant at (202)
551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters or with any other
questions.
 Mark Jensen
American Resources Corp
May 14, 2019
Page 3

FirstName LastNameMark Jensen          Sincerely,
Comapany NameAmerican Resources Corp
                                       Division of Corporation Finance
May 14, 2019 Page 3                    Office of Telecommunications
FirstName LastName