Mail Stop 4628

                                                             September 14, 2018

Via Facsimile
Athanasios Feidakis
President and Chief Executive Officer
Globus Maritime Limited
128 Vouliagmenis Ave., 3rd Floor
166 74
Glyfada, Athens
Greece

       Re:     Globus Maritime Limited
               Form 20-F for the Fiscal Year Ended December 31, 2017
               Filed March 9, 2018
               File No. 1-34985

Dear Mr. Feidakis:

        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.

Risk Factors, page 8
Our vessels may call on ports located in countries that are subject to
sanctions..., page 35


   1. You disclose that from time to time, on charterer's instructions, your
vessels may call on
      ports located in Syria, Sudan and North Korea, and in your letter to us
dated January 5,
      2016, you discussed a port call by one of your vessels to Sudan. As you
disclose, Sudan,
      Syria and North Korea are designated by the U.S. Department of State
Department as
      state sponsors of terrorism and are subject to U.S. sanctions and/or
export controls.
      Please describe to us the nature and extent of any past, current, and
anticipated contacts
      with Sudan, Syria and North Korea since your 2016 letter, including with
their
 Athanasios Feidakis
Globus Maritime Limited
September 14, 2018
Page 2

       governments, whether through subsidiaries, charterers, affiliates, or
other direct or
       indirect arrangements. Please also discuss the materiality of any
contacts, 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 Sudan, Syria and North
Korea for the last
       three fiscal years and the subsequent interim period.

        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 Jennifer Hardy, Special Counsel, at (202) 551-3767 or
me at (202) 551-
3470 if you have any questions about the comments or our review.

                                                            Sincerely,

                                                            /s/ Cecilia Blye

                                                            Cecilia Blye, Chief
                                                            Office of Global
Security Risk

cc:    Anne Nguyen Parker
       Assistant Director