August 12, 2019

Tony Lauro II
Chief Financial Officer
International Money Express, Inc.
9480 South Dixie Highway
Miami, Florida 33156

       Re: International Money Express, Inc.
           Registration Statement on Form S-3
           Filed July 30, 2019
           File No. 333-232888

Dear Mr. Lauro II:

       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
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       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 S-3

Description of the Debt Securities
Governing Law, page 14

1.     We note your disclosure that the indenture will include jury trial
waiver and exclusive
       forum provisions. Please confirm, if true, that the jury waiver and
exclusive forum
       provisions are not intended to apply to claims under the U.S. federal
securities laws. With
       regards to the exclusive forum provision, if it does not apply to
actions arising under the
       Securities Act or Exchange Act, please ensure that the exclusive forum
provision in the
       indenture states this clearly, or tell us how you will inform investors
in future filings that
       the provision does not apply to any actions arising under the Securities
Act or Exchange
       Act. If the provisions do apply to claims under the U.S. federal
securities laws, please
       clearly disclose this in your filing and indenture and provide risk
factor disclosure in your
 Tony Lauro II
International Money Express, Inc.
August 12, 2019
Page 2
         registration statement related to these provisions, including but not
limited to the
         enforceability of the provisions, increased costs to bring a claim,
limited access to
         information and other imbalances of resources between the company and
         and that these provisions can discourage claims or limit shareholders
ability to bring a
         claim in a judicial forum that they find favorable. This comment also
applies to the
         disclosure on page 6 regarding the exclusive forum provision included
in your charter.
Selling Stockholders, page 15

2.       We note your disclosure on page 18 that "[t]he applicable prospectus
supplement will
         identify the Selling Stockholders." However, you do not appear
eligible to rely on
         Securities Act Rule 430B(b) to omit selling shareholder disclosure
with respect to the
         resale offering of your common stock. In this regard, please note that
companies that
         were shell companies during the past three years may not omit this
information under
         Rule 430B(b)(2)(iv) of the Securities Act of 1933, as amended. Please
revise throughout
         the prospectus to include the number of shares registered for resale
and include the list of
         selling shareholders in this section.
Information Incorporated by Reference , page 20

3.       Please incorporate by reference your current report on Form 8-K filed
July 30, 2019.
         Refer to Item 12(a) of Form S-3.
        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

       Please contact Jennifer Lopez, Staff Attorney, at 202-551-3792 or Mara
Assistant Director, at 202-551-3264 with any questions.

FirstName LastNameTony Lauro II                                Sincerely,
Comapany NameInternational Money Express, Inc.
                                                               Division of
Corporation Finance
August 12, 2019 Page 2                                         Office of
Consumer Products
FirstName LastName