September 3, 2019
Via E-mail
Kirt Gardner
Chief Financial Officer
UBS Group AG
Bahnhofstrasse 45, CH-8001
Zurich
Switzerland

       Re:     UBS Group AG
               UBS AG
               Forms 20-F for the Fiscal Year Ended December 31, 2018
               Filed March 15, 2019
               File Nos. 1-36764 and 1-15060

Dear Mr. Gardner:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

General

   1. Please describe to us the nature and extent of any past, current, and
anticipated contacts
      with Syria and Sudan since our 2016 review, including contacts with those
countries'
      governments, whether through subsidiaries, affiliates, or other direct or
indirect
      arrangements. As you are aware, Syria and Sudan are designated by the
U.S. Department
      of State as state sponsors of terrorism and are subject to U.S. economic
sanctions and/or
      export controls. Your Form 20-F does not provide disclosure about those
countries.

   2. Please discuss the materiality of any contacts with Syria and Sudan in
quantitative terms
      and in terms of qualitative factors that a reasonable investor would deem
important in
      making an investment decision. Tell us the approximate dollar amounts of
any revenues,
      assets and liabilities associated with those countries for the last three
fiscal years and the
 Kirt Gardner
UBS Group AG
September 3, 2019
Page 2

         subsequent interim period. Address for us the potential impact of the
investor sentiment
         evidenced by divestment and similar initiatives that have been
directed toward companies
         that have operations associated with state sponsors of terrorism.

         We urge all persons who are responsible for the accuracy and adequacy
of the disclosure
in the filing to be certain that the filing includes the information the
Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its
management are
in possession of all facts relating to a company's disclosure, they are
responsible for the accuracy
and adequacy of the disclosures they have made.

      In responding to our comments, please provide a written statement from
the company
acknowledging that:

         the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

         staff comments or changes to disclosure in response to staff comments
do not foreclose
         the Commission from taking any action with respect to the filing; and

         the company may not assert staff comments as a defense in any
proceeding initiated by
         the Commission or any person under the federal securities laws of the
United States.

        You may contact Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:      Todd Tuckner, Controller
         UBS Group AG

         Pamela Long
         Assistant Director