Mail Stop 4628

                                                             May 6, 2019

Via E-mail
Michael P. Santomassimo
Chief Financial Officer
The Bank of New York Mellon Corporation
240 Greenwich Street
New York, New York 10286

       Re:     The Bank of New York Mellon Corporation
               10-K for Fiscal Year Ended December 31, 2018
               February 27, 2019
               File No. 1-35651

Dear Mr. Santomassimo:

        We have limited our review of your filing to your contacts with
countries that have been
identified as state sponsors of terrorism, and we have the following comments.
Our review with
respect to this issue does not preclude further review by the Assistant
Director group with respect
to other issues. In our comments, we 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.

General

1.     In letters to the staff dated September 23, 2013 and May 19, 2016, you
discussed limited
       contacts with Sudan and Syria. As you know, Sudan and Syria are
designated by the
       Department of State as state sponsors of terrorism, and are subject to
U.S. economic
       sanctions and/or export controls. Please describe to us the nature and
extent of your past,
       current and anticipated contacts with those countries since your 2016
letter, including
       contacts with their governments, whether through subsidiaries, partners,
customers or other
       direct or indirect arrangements. In this regard, we note that Byblos
Bank, which on its
       website provides information about majority-owned subsidiaries in Sudan
and Syria,
       identified Bank of New York Mellon as a correspondent bank in its 2017
annual report.

       Additionally, we are aware of a news report stating that a federal court
granted U.S.
       prosecutors' application for "damming" seizure warrants against banks
including Bank of
 Michael P. Santomassimo
The Bank of New York Mellon Corporation
May 6, 2019
Page 2
       New York Mellon, to seize millions of dollars associated with several
companies that deal
       with North Korea. North Korea is a U.S.-designated state sponsor of
terrorism, and is subject
       to U.S. economic sanctions and export controls. Please describe to us
the nature and extent
       of your past, current, and anticipated contacts with North Korea, if
any, including contacts
       with its governments, whether through subsidiaries, partners, customers
or other direct or
       indirect arrangements.

2.     Please discuss the materiality of any contacts with North Korea, Sudan
and Syria, 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
       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 U.S.-designated state
sponsors of terrorism.

        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 Daniel Leslie, Staff Attorney, at (202) 551-3876 or me
at (202) 551-
3470 if you have any questions about the comment or our review.

                                                             Sincerely,

                                                             /s/ Cecilia Blye

                                                             Cecilia Blye,
Chief
                                                             Office of Global
Security Risk

cc:    Kathleen McCabe
       Chief Securities Counsel,
       Manning Director and Associate General Counsel
       The Bank Of New York Mellon Corporation