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                             March 7, 2022

       Jeffery D. Johnson
       Chief Executive Officer
       Cuentas Inc.
       235 Lincoln Rd., Suite 210
       Miami Beach, FL 33139

                                                        Re: Cuentas Inc.
                                                            Registration
Statement on Form S-3
                                                            Filed February 14,
2022
                                                            File No. 333-262727

       Dear Mr. Johnson:

              We have limited our review of your registration statement to
those issues we have
       addressed in our 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.

       Registration Statement on Form S-3 Filed February 14, 2022

       General

   1.                                                   Please update your
financial statements and related financial information in accordance
                                                        with Rule 8-08(b) of
Regulation S-X. You will need to include your audited financial
                                                        statements or file and
incorporate by reference your annual report for fiscal year ended
                                                        December 31, 2021
before we will accelerate the effective date of your registration
                                                        statement.
 Jeffery D. Johnson
FirstName   LastNameJeffery D. Johnson
Cuentas Inc.
Comapany
March       NameCuentas Inc.
       7, 2022
March2 7, 2022 Page 2
Page
FirstName LastName
2.       We note that you have included financial statements for SDI Black as
of and for the years
         ended December 31, 2020 and 2019 and for the interim period ended
September 30,
         2021. Please update to include the financial statements for the two
most recent fiscal
         years and pro forma information as required by Rule 3-05 and Article
11 of Regulation S-
         X.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Cara Wirth at (202) 551-7127 or Jennifer L  pez Molina at
(202) 551-3792
with any questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Trade &
Services
cc:      Matthew Bernstein