January 6, 2020

Ran Daniel
Chief Financial Officer
Cuentas, Inc.
200 S. Biscayne Blvd., Suite 5500
Miami, FL 33131

       Re: Cuentas, Inc.
           Preliminary Proxy Statement on Schedule 14A
           Filed December 10, 2019
           File No. 000-54923

Dear Mr. Daniel:

       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.

Preliminary Proxy Statement on Schedule 14A filed December 10, 2019

General

1.    We note that certain proposals relate to your authorized capital stock.
However, it is
      difficult to discern the current number of authorized shares based upon
your previous
      disclosures and your charter amendments filed on EDGAR. For example, we
note that
      while page F-20 of your Form 10-K for the fiscal year ended December 31,
2016 discloses
      that you amended your Articles of Incorporation to decrease your
authorized number of
      common shares from 9,500,000,000 to 360,000,000, it does not appear that
the
      corresponding charter amendment has been filed as an exhibit on EDGAR.
Similarly, we
      note that while the Definitive Proxy Statement filed on June 29, 2018
relates to a charter
      amendment to authorize blank check preferred stock, it does not appear
that the
      amendment was subsequently filed as an exhibit. Please tell us where the
charter
      amendments authorizing 360,000,000 shares of common stock and 50,000,000
shares of
 Ran Daniel
Cuentas, Inc.
January 6, 2020
Page 2

      "blank check" preferred stock have been filed. Note that you are required
to file full and
      complete copies of all charter documents, as amended.
2.    Please revise your description of the proposal to amend and restate the
company s bylaws
      to discuss each proposed change in greater detail. Your revised
disclosure should clearly
      state how the amended and restated bylaws would differ from the current
bylaws and how
      the proposed changes would ensure that your bylaws are "more consistent"
with Florida
      law.
        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 Daniel Morris at (202) 551-3314 or Jennifer L pez at
(202) 551-3792 with
any questions.



                                                            Sincerely,
FirstName LastNameRan Daniel
                                                            Division of
Corporation Finance
Comapany NameCuentas, Inc.
                                                            Office of Trade &
Services
January 6, 2020 Page 2
cc:       David Selengut, Esq.
FirstName LastName