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AXIS Capital Holdings Limited

92 Pitts Bay Road
Pembroke, HM 08
P.O. Box HM 1254
Hamilton HM FX, Bermuda

May 3, 2019

U.S. Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C. 20549

Re:
Notice of disclosure filed in Quarterly Report under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Securities Exchange Act of 1934, as amended

Ladies and Gentlemen:

Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Securities Exchange Act of 1934, as amended, notice is hereby provided that AXIS Capital Holdings Limited has made disclosure pursuant to such provisions in its Quarterly Report on Form 10-Q for the quarter ended March 31, 2019, which was filed with the Securities and Exchange Commission on May 3, 2019.

Respectfully submitted,
AXIS Capital Holdings Limited

By: /s/ Conrad D. Brooks
Conrad D. Brooks
General Counsel