April 2, 2019

Gordon Lee
Chief Executive Officer
AGBA Acquisition Ltd.
Room 1108, Eleventh Floor
New Mandarin Plaza, 14 Science Museum Road
Tsimshatsui East, Kowloon
Hong Kong

       Re: AGBA Acquisition Ltd.
           Draft Registration Statement on Form S-1
           Filed on March 11, 2019
           CIK No. 0001769624

Dear Mr. Lee:

       We have reviewed your draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

      After reviewing the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1, filed on March 11, 2019, CIK no.
0001769624

Background and Competitive Advantages, page 2

1.     Please revise the first paragraph to clarify that the management team
you reference may
       not remain with the company following any business combination
transaction.
Risk Factors, page 17

2.     We note that you plan to focus on operating businesses that have their
principal operations
       in China, in the healthcare, education, entertainment, and financial
services. Please
       provide more fulsome risk factor disclosure relating to the principal
risks the company
 Gordon Lee
AGBA Acquisition Ltd.
April 2, 2019
Page 2
      may face by virtue of operating in China, including in some instances in
industries that are
      on the prohibited list. As necessary, please provide risk factor
disclosure relating to the
      possibility of employing a VIE structure to conduct your operations.
General

3.    We note references to third-party market data throughout your draft
prospectus, including
      for example at page 2, where you reference several reports, including
those prepared by
      Trading Economics and McKinsey & Company. Please provide us with copies
of any
      materials that support third-party statements, clearly cross-referencing
a statement with
      the underlying factual support. Please advise us if any of the reports
cited within your
      prospectus were commissioned by the company.
4.    Please supplementally provide us with copies of all written
communications, as defined in
      Rule 405 under the Securities Act, that you, or anyone authorized to do
so on your behalf,
      present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or
      not they retain copies of the communication.
        You may contact Charles Eastman, Staff Accountant, at 202-551-3794, or
Robert S.
Littlepage, Accountant Branch Chief, at 202-551-3361, if you have questions
regarding
comments on the financial statements and related matters. Please contact Paul
Fischer, Staff
Attorney, at 202-551-3415, or Celeste M. Murphy, at 202-551-3257, with any
other questions.



                                                            Sincerely,
FirstName LastNameGordon Lee
                                                            Division of
Corporation Finance
Comapany NameAGBA Acquisition Ltd.
                                                            Office of
Telecommunications
April 2, 2019 Page 2
cc:       Giovanni Caruso
FirstName LastName