October 18, 2024

Koh Kuan Hua
Chairman and Chief Executive Officer
Uni-Fuels Holdings Ltd
15 Beach Road, Beach Centre #05-07
Singapore 189677

       Re: Uni-Fuels Holdings Ltd
           Amendment No. 2 to Draft Registration Statement on Form F-1
           Submitted October 3, 2024
           CIK No. 0002021688
Dear Koh Kuan Hua:

     We have reviewed your amended draft registration statement and have the
following
comment(s).

       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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our June 18, 2024 letter.

Amendment No. 2 to Draft Registration Statement on Form F-1 submitted October
3, 2024
Prospectus Summary
Our Corporate Structure and History, page 5

1.     We note the revisions to your corporate structure diagrams to include
the minority
       shareholders. Please revise the diagram and elsewhere throughout your
registration
       statement as appropriate to reflect the names of the five minority
shareholders and
       disclose whether they are related parties, as applicable. If helpful,
consider the use of
       footnotes.
 October 18, 2024
Page 2
Capitalization, page 37

2.     Please tell us your consideration of including debt in your calculation
of total
       capitalization. Refer to Item 3.B. of Form 20-F.
Principal Shareholders, page 86

3.     Please note that beneficial ownership information is to be provided for
each beneficial
       owner of 5% or more of each class of the company   s voting securities.
In this regard,
       we note that you have five minority shareholders who appear to
collectively own (in
       equal amounts) all of your outstanding Class A Ordinary Shares. Please
revise to
       include the required information for these major shareholders. Refer to
Item 7.A.1 of
       Form 20-F.
Consolidated Financial Statements for the Years Ended December 31, 2023 and
2022
Notes to Consolidated Financial Statements
9. Shareholders' Equity
Ordinary shares, page F-17

4.     We note from your disclosure on September 3, 2024, 29,999,999 shares of
Class B
       shares with a par value of $0.0001 were issued. Please tell us your
basis for
       accounting for the issuance of these shares on a retrospective basis. In
addition, please
       tell us your consideration of ASC 505-20.

       Please contact Tony Watson at 202-551-3318 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please contact Kate Beukenkamp at 202-551-3861 or Donald Field at
202-551-3680
with any other questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
cc:   Lawrence S. Venick