August 15, 2019

Inger M. Klemp
Principal Financial Officer and Principal Accounting Officer
Frontline LTD
Par-la-Ville Place
14 Par-la-Ville Road
Hamilton, HM 08
Bermuda

       Re: Frontline LTD
           Form 20-F for Fiscal Year Ended December 31, 2018
           Filed March 28, 2019
           File No. 001-16601

Dear Mr. Klemp:

       We have reviewed your filing 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 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.

Form 20-F for Fiscal Year Ended December 31, 2018

Item 5. Operating and Financial Review and Prospects
B. Liquidity and Capital Resources
Cash Flows
Net cash provided by operating activities, page 59

1.    Please provide a comparative analysis of material year to year changes in
net cash
      provided by operating activities for all periods presented. In this
regard, we note
      operating cash flow decreased by $84 million, or approximately 65%,
between 2018 and
      2017 and decreased $155 million, or 54%, between 2017 and 2016.

      In connection with the above, your current disclosure on page 59 mentions
reliance on the
      spot market and changes in TCE rates contributing to fluctuations in cash
flows of
 Inger M. Klemp
Frontline LTD
August 15, 2019
Page 2
         operating activities. However, it is not clear how changes in rates
were the cause of
         decreased operating cash flow in 2018 compared 2017. Disclosure on
page 39 in regard
         to rates for various classes of vessels appears to indicate a net
increase in rates between
         2018 and 2017, and you reported a net increase in voyage and time
charter revenues in
         2018 from 2017. Your analysis should cite and quantify all material
factors affecting
         operating cash and discuss any material drivers underlying those
factors. Additionally,
         clearly explain how actual operating cash is impacted by them if not
apparent. Please note
         that merely citing changes in working capital items and other items
identified in the
         statement of cash flows may not provide a sufficient basis to
understand how operating
         cash between comparative periods changed.

         Refer to section III.D of Release No. 33-6835, section IV.B.1 of
Release No. 33-8350 and
         section 501.04 of the staff's Codification of Financial Reporting
Releases for guidance in
         regard to all of the preceding.


        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.

       You may contact Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
if you
have questions regarding comments on the financial statements and related
matters, or any other
questions.



FirstName LastNameInger M. Klemp                              Sincerely,
Comapany NameFrontline LTD
                                                              Division of
Corporation Finance
August 15, 2019 Page 2                                        Office of
Transportation and Leisure
FirstName LastName