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                            February 26, 2021

       Kai Cheong Wong
       Chief Executive Officer
       AsiaFin Holdings Corp.
       Suite 30.02, 30th Floor, Menara KH (Promet)
       Jalan Sultan Ismail, 50250 Kuala Lumpur, Malaysia

                                                        Re: AsiaFin Holdings
Corp.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed February 8,
2021
                                                            File No. 333-251413

       Dear Mr. Wong:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
January 14, 2021 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed February 8,
2021

       Business Information, page 17

   1.                                                   We re-issue our prior
comment 2, and have the following comments based on your revised
                                                        disclosures in response
to our comment:

                                                              Please revise
your Government Regulations section to discuss the effects of the
                                                            various regulations
that you disclose there on your business, so that investors can
                                                            understand how the
regulations are applicable to you, as well as the nature and degree
                                                            of impact of such
regulations on your business. Additionally, please consider
                                                            significantly
expanding your disclosure in this section to provide a more robust
                                                            discussion of the
material Hong Kong and Malaysian laws and regulations to which
 Kai Cheong Wong
AsiaFin Holdings Corp.
February 26, 2021
Page 2
              your business is subject to including, but not limited to,
acquiring necessary permits
              or licenses, intellectual property rights, regulation affecting
foreign-based businesses
              operating in Hong Kong and Malaysia and/or tax issues. To the
extent your company
              has not yet obtained all required licenses, permits or approvals,
please clearly
              describe the foregoing.

                As a related matter, please add risk factor disclosure
addressing the risks or known
              concerns relating to the regulatory environment in Hong Kong and
Malaysia,
              including, but not limited to, risks related to acquiring
necessary permits or
              licenses, the interpretation and enforcement of laws and
regulations, challenges to
              protecting intellectual property rights, unfavorable tax
consequences for non-citizen
              shareholders, restrictions on foreign investment, and the ability
to transfer funds into
              or out of the country. Additionally, consider any other Hong Kong
or Malaysian
              laws, regulations or customs that could present material risks to
your business.

                Please also add a risk factor that addresses limitations on the
ability of U.S.
              regulators, such as the Department of Justice, the SEC, the PCAOB
and other
              authorities, to conduct investigations and inspections within
Hong Kong.

         For additional guidance, refer to Item 101(h)(4)(viii) and (ix) of
Regulation S-K, as well
         as CF Disclosure Guidance: Topic No. 10.
Description of Business, page 17

2.       We note your revised disclosures in response to prior comment 4, and
partially re-issue
         our comment. Your revised disclosures indicate that you generated all
of your revenue
         from two customers for your fiscal year ended August 31, 2020, and
that related party
         transactions represented all your revenue during such period. Please
disclose this
         information where you discuss your "present clients," including in
your Prospectus
         Summary, as well as your Description of Business and Results of
Operations sections.
Certain Relationships and Related Transactions, page 28

3.     Revise this section to include all transactions since the beginning of
the last fiscal year, or
       any currently proposed transaction, with related persons. See Item
404(d) of Regulation
       S-K.
FirstName LastNameKai Cheong Wong
Financial Statements, page F-1
Comapany NameAsiaFin Holdings Corp.
4.     Please
February       update
          26, 2021    your
                   Page  2 financial statements in accordance with Rule 8-08 of
Regulation S-X.
FirstName LastName
 Kai Cheong Wong
FirstName LastNameKai
AsiaFin Holdings Corp. Cheong Wong
Comapany26,
February  NameAsiaFin
            2021       Holdings Corp.
February
Page 3 26, 2021 Page 3
FirstName LastName
       You may contact Patrick Kuhn at (202) 551-3308 or Angela Lumley at (202)
551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Lamparski at (202) 551-4695 or Erin Jaskot at (202) 551-3442
with any other
questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services