ubsgroupag.20f.ogsr.letter

UBS Group AG

UBS AG

Postfach

8098 Zürich

Group CFO

Kirt Gardner

Tel: +41-44-237-3791

kirt.gardner@ubs.com

Group Controller and Chief Accounting Officer

Todd Tuckner

Tel: +203-719-0381

todd.tuckner@ubs.com

www.ubs.com

Ms. Cecilia Blye, Chief

Office of Global Security Risk

Securities and Exchange Commission

100 F Street, NE

Washington DC 20549-1090

Re: UBS Group AG

UBS AG

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

Filed March 15, 2019

File Nos. 1-36764 and 1-15060

September 17, 2019

Dear Ms. Blye,

We respectively submit a response to your letter dated September 3, 2019 from the staff of the Securities and Exchange Commission relating to Form 20-F for the Fiscal Year Ended December 31, 2018, filed March 15, 2019.

1. Please describe to us the nature and extent of any past, current, and anticipated contacts with Syria and Sudan since our 2016 review, including contacts with those countries' governments, whether through subsidiaries, affiliates, or other direct or indirect arrangements. As you are aware, Syria and Sudan are designated by the

U.S. Department of State as state sponsors of terrorism and are subject to U.S. economic sanctions and/or export controls. Your Form 20-F does not provide disclosure about those countries.

UBS has no past, current, or anticipated contact with the Subject Countries, either directly or through subsidiaries, affiliates, customers or direct or indirect arrangements, apart from those that may be licensed or otherwise permitted by the U.S. Department of the Treasury, Office of Foreign Assets Control ("OFAC") as set forth below in response to SEC Question 2.

UBS Group AG and UBS AG ("UBS" or the "Bank") do not have a subsidiary or affiliate, employees, or other physical presence in either Syria or Sudan (the "Subject Countries"). UBS maintains a Group Sanctions Policy (the "Policy") that prohibits transactions involving Syria and transactions involving the Government of Sudan. Pursuant to the Policy, UBS restricts dealings with clients where the Bank could provide benefit to the foregoing. UBS's know-your-customer policies also require that additional inquiries be made where there are indications that a client has dealings in or with a sanctioned country or government. The Bank's systems and controls are designed to prevent

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transactions involving the Subject Countries and sanctioned parties. Additionally, the Bank performs periodic reviews of our clients to ensure that any new potential risks are identified and promptly addressed. These systems, controls, and reviews are subject to regular audit and testing.

2. Please discuss the materiality of any contacts with Syria and Sudan in quantitative terms and in terms of qualitative factors that a reasonable investor would deem important in making an investment decision. Tell us the approximate dollar amounts of any revenues, assets and liabilities associated with those countries for the last three fiscal years and the subsequent interim period. Address for us the potential impact of the investor sentiment evidenced by divestment and similar initiatives that have been directed toward companies that have operations associated with state sponsors of terrorism.

We do not believe that any activities involving the Subject Countries, individually or in the aggregate, constitute a material risk to our security holders. UBS has no relationships with the governments, state-owned enterprises, or banks of the Subject Countries. UBS AG and UBS Switzerland AG hold a small number of legacy private accounts for persons domiciled in Syria with whom it transacts in accordance with a specific OFAC license. Sudan is no longer subject to comprehensive U.S. sanctions and accordingly the Bank’s small number of relationships with those domiciled in Sudan (e.g. international organization employees on mission) do not require OFAC general or specific licensing.

Below is information concerning UBS's global exposure to Sudan and Syria. We consider our exposure to these Subject Countries to be immaterial relative to our overall business and in compliance with sanctions requirements as explained in the paragraph above:

USD	31-Dec-16		31-Dec-17		31-Dec-18		30-Jun-19
	Sudan	Syria	Sudan	Syria	Sudan	Syria	Sudan	Syria
Revenues	14,608	78,710	26,067	149,150	23,788	118,254	23,357	45,542
Client Assets	2,054,376	11,688,267	2,078,920	9,677,352	4,028,235	10,605,347	5,094,351	9,759,079
Assets	3,000	28,000	5,000	10,000	248,000	804,000	2,000	810,000
Liabilities	- 2,118,000	- 5,090,000	- 1,853,000	- 4,016,000	- 1,701,000	- 4,434,000	- 2,391,000	- 4,322,000

With respect to various US state divestment laws or similar initiatives that require divestment from, or reporting of interests in, companies that do business with state sponsors of terrorism, we believe that our Group Sanctions Policy and relevant systems and controls are appropriately designed to comply with US sanctions globally and thus prevent the underlying activity that would trigger concerns from a divestment perspective.

We appreciate the opportunity to provide you with this additional information. If you wish to discuss any of our responses or require further information, please do not hesitate to contact Todd Tuckner at +1 203-719-0381 (todd.tuckner@ubs.com).

Yours sincerely,

UBS Group AG

/s/ Kirt Gardner /s/ Todd Tuckner

Kirt Gardner Todd Tuckner

Group Chief Financial Officer Group Controller and Chief Accounting Officer