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                              October 20, 2022

       Shachar Daniel
       Chief Executive Officer
       Safe-T Group Ltd.
       8 Abba Eban Ave.
       Herzliya
       4672526 Israel

                                                        Re: Safe-T Group Ltd.
                                                            Registration
Statement on Form F-3
                                                            Filed September 23,
2022
                                                            File No. 333-267580

       Dear Shachar Daniel:

              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 F-3 filed September 23, 2022

       ORB Funding, page 1

   1.                                                   Please revise to
describe all material terms of the ORB funding agreement, including the
                                                        vesting schedule. For
example, we note that Section 3.2.4 of the agreement provides
                                                        examples of different
potential outcomes with respect to ORB's exercise of warrants under
                                                        the vesting schedule.
Your revised disclosure should clearly describe the intended vesting
                                                        schedule and these
examples.
   2.                                                   Please provide us with
your analysis as to your eligibility to register the resale of the ADS
                                                        representing ordinary
shares underlying the warrants pursuant to the ORB Agreement. As
                                                        part of your response,
disclose the dates on which the warrants were issued and why you
 Shachar Daniel
Safe-T Group Ltd.
October 20, 2022
Page 2
      believe the private placement has been completed given the vesting
schedule and
      requirement to achieve certain milestones. In a PIPE transaction, a
registered resale of
      securities is permitted where the investor is irrevocably bound to
purchase a set number of
      securities for a set purchase price that is not based on a market price
or a fluctuating ratio.
      In addition, there can be no conditions that an investor can cause not to
be satisfied,
      including conditions related to market price of the securities or
investor   s satisfactory
      completion of its due diligence requirements. For guidance, refer to
Securities Act
      Sections Compliance & Disclosure Interpretation 139.11.
Exhibits

3.    Please file the ORB funding agreement as an exhibit.
        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 Austin Pattan, Staff Attorney, at (202) 551-6756 or Jan
Woo, Legal
Branch Chief, at (202) 551-3453 with any other questions.



                                                             Sincerely,
FirstName LastNameShachar Daniel
                                                             Division of
Corporation Finance
Comapany NameSafe-T Group Ltd.
                                                             Office of
Technology
October 20, 2022 Page 2
cc:       Howard Berkenblit
FirstName LastName