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                            September 12, 2022

       Victor Hoo
       Chief Executive Officer
       VCI Global Limited
       B03-C-8 Menara 3A
       KL Eco City, No. 3 Jalan Bangsar
       59200 Kuala Lumpur

                                                        Re: VCI Global Limited
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted August
16, 2022
                                                            CIK No. 0001930510

       Dear Mr. Hoo:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1

       Risk Factors, page 20

   1.                                                   We note your amended
disclosure in response to comment 10 and your response regarding
                                                        your intention not to
expand into jurisdictions other than Malaysia. Please revise your
                                                        disclosure to confirm
in which jurisdictions you intend to operate and tailor your
                                                        disclosure to those
jurisdictions. For example, we note your disclosure regarding the U.S.
                                                        consulting market.
Please tell us why you believe the information regarding non-
                                                        Malaysian markets is
material to investors in your offering. We also note your disclosure
                                                        that you engage with
clients from China, Singapore and the United States. Please
                                                        reconcile the
disclosure to clarify where you operate.
 Victor Hoo
VCI Global Limited
September 12, 2022
Page 2
General

2.    We note your response to comment 22 and have the following additional
questions:

         (a) Please supplementally provide us with a full detailed
calculation/analysis of the
      value (as defined in Section 2(a)(41) of the Investment Company Act of
1940) of your
         investment securities    (as per Section 3(a)(1)(C) of the 1940 Act)
as a percentage of the
      value of your total assets (exclusive of Government securities, as
defined in the 1940 Act,
      and cash items) on an unconsolidated basis. In your analysis, please
specifically identify
      which assets are included as investment securities and which are not, and
also please
      itemize what is included as a cash item and the value for each cash item
individually. In
      your calculation, please indicate whether, and if so which, subsidiaries
fall under
      subsection 3(a)(2)(C) of the 1940 Act.

         (b) If you are relying on exclusion or exception from investment
company status under
      the 1940 Act, please provide a detailed legal analysis of the basis for
your reliance on any
      such exclusion or exception.

         (c) We note your response to comment 22 says you have a 14.55% equity
interest in
      Treasure Global Inc. Please supplementally describe the nature of this
investment in
      greater detail. Please also indicate whether you derives any revenue from
your investment
      in Treasure Global Inc.

         (d) Page 4 of your draft registration statement refers to    sourcing
for investment
      opportunities    in a section called    Investments." Please describe how
the activities
      referenced under    Investments    relate to the Tonopah factors
identified in the comment 22
      response.
3.    Your draft registration statement states that you have a    key advisory
practice[] in . . .
      investment.    Please provide us with your legal analysis as to whether
you are an
         investment adviser    as defined by section 202(a)(11) of the
Investment Advisers Act of
      1940.
       You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at
202-551-3398 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Alyssa Wall at 202-551-8106 or Dietrich King at 202-551-8071 with any
other questions.



                                                            Sincerely,
FirstName LastNameVictor Hoo
                                                            Division of
Corporation Finance
Comapany NameVCI Global Limited
                                                            Office of Trade &
Services
September 12, 2022 Page 2
cc:       Jeffrey P. Wofford, Esq.
FirstName LastName