December 19, 2019

Ola Lorentzon
Interim Chief Executive Officer
Golden Ocean Group Ltd.
Par-la-Ville Place
14 Par-la-Ville Road
Hamilton HM 08
Bermuda

       Re: Golden Ocean Group Ltd.
           Form 20-F for the Fiscal Year ended December 31, 2018
           Filed March 22, 2019
           File No. 000-29106

Dear Mr. Lorentzon:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 the Fiscal Year ended December 31, 2018

Financial Statements
Note 2 - Summary of Significant Accounting Policies, page F-11
Revenue Recognition, page F-12

1.    We note your accounting policy for revenue sharing/pool agreements on
page F-13,
      indicating that revenues and expenses of the pools are presented gross
when you are the
      principal, while allocations that you receive when you are not the
principal are presented
      as other operating income, net. We understand from your disclosures on
pages 36 and 39
      that you had 25 of your 77 vessels operating under such agreements at
year-end.

      Tell us the amounts of your revenues and expenses for each period that
relate to revenue
      sharing/pool agreements in which you were the manager/principal, and the
amounts of
 Ola Lorentzon
Golden Ocean Group Ltd.
December 19, 2019
Page 2
         such revenues and expenses that you retained based on your share of
the pools. Tell
         us how you report your allocations of amounts attributable/distributed
to other participants
         in these pools, along with your rationale.

         Please expand your policy disclosure to describe the scope of your
responsibilities as the
         manager/principal in these arrangements, also to clarify your
reference to "under the
         charter parties" along with your gross and net reporting policy
considerations.

         Please clarify whether amounts shown on the line item "other operating
income, net" are
         limited to the allocations you receive as a participant/agent, or also
include your
         allocations as a manager/principal to other participants. Provide us
with details of the
         amounts reported on this line for each period.

         In order for us to better understand your accounting policy
considerations, please submit
         copies of the two revenue sharing/pool agreements that were the most
significant during
         2018, in your role as a manager/principal, and separately, as a
participant/agent.
       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.

      You may contact Joseph Klinko, Staff Accountant, at 202-551-3824, Lily
Dang, Staff
Accountant, at 202-551-3867 or Karl Hiller, Branch Chief, at 202-551-3686 with
any questions.



FirstName LastNameOla Lorentzon                                Sincerely,
Comapany NameGolden Ocean Group Ltd.
                                                               Division of
Corporation Finance
December 19, 2019 Page 2                                       Office of Energy
& Transportation
FirstName LastName