Mailstop 3561
                                                               September 13,

    Robert Lisy
    Chief Executive Officer
    International Money Express, Inc.
    9480 South Dixie Highway
    Miami, Florida 33156

            Re:      International Money Express, Inc.
                     Registration Statement on Form S-1
                     Filed August 20, 2018
                     File No. 333-226948

    Dear Mr. Lisy:

           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

           After reviewing any amendment to your registration statement and the
information you
    provide in response to these comments, we may have additional comments.


        1. Please revise your prospectus to clarify whether you are registering
common stock for
           sale in a primary offering only or whether you are conducting both a
primary offering and
           a secondary offering by selling shareholders. In this regard, we
note your disclosure that
           you will receive net proceeds from the exercise of the warrants but
not from the sale of
           the underlying shares. To the extent you are conducting a secondary
offering, please
           revise your prospectus to provide the disclosures required by Item
507 of Regulation S-K.

    Incorporation By Reference, page 89

        2. Please revise your prospectus to remove this section or provide us
with your analysis
           regarding your eligibility to incorporate by reference on Form S-1.
In this regard, we
           note that companies that were either shell companies or blank check
companies during
 Robert Lisy
International Money Express, Inc.
September 13, 2018
Page 2

        the past three years are ineligible to incorporate by reference on Form
S-1. Please refer
        to General Instruction VII.D of Form S-1.

        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 Danilo Castelli, Staff Attorney, at (202)551-6521,
Jennifer L pez-Molina,
Staff Attorney, at (202)551-3792 or me at (202)551-3720 with any other


                                                             /s/ Jennifer L pez

                                                             Mara L. Ransom
                                                             Assistant Director
                                                             Office of Consumer

cc:     Tony Lauro
        Steven Epstein
        Meredith Mackey