May 24, 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
           Response Letter filed May 20, 2019
           File No. 001-38816

Dear Mr. Jensen:

       We have reviewed your May 20, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in
our May 14, 2019 letter.

Form 10-K for the Year Ended December 31, 2018

Note 1: Summary of Significant Accounting Policies
Basis of Presentation and Consolidation:, page F-8

1.    We note your response to comment two. Please revise your balance sheet
presentation to
      replace the Mine Development caption with the correct description of the
acquired
      property, plant and equipment.
2.    Please amend your filing, as well as your Form 10-Q (as applicable), to
comply with our
      prior comments one, two, three and four.
 Mark Jensen
American Resources Corp
May 24, 2019
Page 2
Form 8-K filed February 22, 2019

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

3.       Please amend your filing to reflect the corrected dates indicated in
your response
         hereunder and your correspondence dated May 6, 2019.
4.       We note your response to comment 5. Asset acquisitions, such as the
subject transaction
         entered into on February 12, 2019, is scoped out of the Business
Combinations guidance.
         Refer to ASC 805-10-15-4(b). Instead, the accounting and valuation of
asset acquisitions
         should be based on the guidance in ASC 718 (as amended, effective
2019) which sets a
         grant date for determining the fair value of equity transactions
including non-employee
         transactions. However, the determination of the grant date shall be
based on the relevant
         facts and circumstances. In setting the grant date of the stock as of
February 12, 2019 (the
         date of the agreements), tell us your consideration of the following:
           the reasons for the stipulated conditions in the agreement,
including but not limited to
             the effectiveness of the Form S-1 and the required NASDAQ listing;
and
           the reasons for the delay in the closing date of the transaction
(February 22, 2019) and
             the events that transpired between the agreement date and the
closing date.

         In addition, in light of the parties' mutual understanding of the key
terms and conditions,
         explain to us why the IPO and NASDAQ listing date (February 15, 2019)
was not deemed
         the grant date of the stock for asset valuation purposes. These
conditions appear to be
         more than just a formality and it is not clear how the grantee could
be affected by
         subsequent changes in the price of the shares prior to this date.
Refer to ASC 718-10-25-5
         and 718-10-55-82 and 83.
        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.



FirstName LastNameMark Jensen                                  Sincerely,
Comapany NameAmerican Resources Corp
                                                               Division of
Corporation Finance
May 24, 2019 Page 2                                            Office of
Telecommunications
FirstName LastName