September 25, 2024

Bea Ordonez
Chief Financial Officer
Payoneer Global Inc.
150 W 30th St
New York , New York , 10001

       Re: Payoneer Global Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Form 10-Q for the Fiscal Period Ended June 30, 2024
           File No. 001-40547
Dear Bea Ordonez:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for the Fiscal Period Ended June 30, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources
Cash Flows
Operating Activities, page 31

1.     It appears your disclosure describes how the reported amount of
operating cash flows was
       derived for each period. Please provide a comparative analysis of the
material factors
       causing a material change in the reported amount of operating cash flows
between
       periods, including material amounts that may offset one another. Refer
to the guidance
       cited above, including the introductory paragraph to Item 303(c) and
(c)(1) of Regulation
       S-K and all applicable instructions to paragraphs (b) and (c).
 September 25, 2024
Page 2
Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Position and Results of
Operations
Liquidity and Capital Resources
Cash Flows
Operating Activities, page 47

2.     Please provide a more fulsome analysis by quantifying the factors cited
for the change in
       reported operating cash flows between periods and discuss underlying
factors associated
       with each cited factor. Refer to Item 303(a) and (b) of Regulation S-K
and all applicable
       instructions to paragraph (b), the introductory paragraph of section
IV.B and all of section
       B.1 of Release No. 33- 8350 and section III.D of Release No. 33-6835. In
so doing,
       clarify how the noncash items cited regarding results and income related
to deferred taxes
       affect operating cash. Also, ensure all material items contributing to
the change are cited.
       For example, in the "Supplemental disclosure of cash flow information"
of the Statement
       of Cash Flows you report you paid over $31 million more in net taxes in
2023 compared
       to 2022 but this was not a factor cited in your analysis.

       In closing, 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.

       Please contact Aamira Chaudhry at 202-551-3389 or Doug Jones at
202-551-3309 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Trade &
Services