Securities Act of 1933
Schedule B

December 9, 2019

Response of the Office of International Corporate Finance
Division of Corporation Finance

Robert S. Risoleo
Sullivan & Cromwell LLP
1700 New York Avenue, NW
Suite 700
Washington, DC 20006

Re: Asian Infrastructure Investment Bank
Incoming letter dated December 6, 2019

Dear Mr. Risoleo:

We are responding to your request dated December 6, 2019. Unless otherwise noted, capitalized terms in this letter have the same meaning as in your request

Based on the facts presented, the Division will not object if the Asian Infrastructure Investment Bank files with the Commission annual reports on Form 18-K under the Securities Exchange Act of 1934 and amendments to those annual reports on Form 18-K/A, and if the Asian Infrastructure Investment Bank incorporates by reference those reports into registration statements, including shelf registration statements, and related prospectuses filed with the Commission under the Securities Act of 1933, all as described in your letter.

This position is based on the representations made to the Division in your request. Any different facts or conditions might require the Division to reach a different conclusion.