United States securities and exchange commission logo
April 5, 2023
Fernando Rodrigo Baron
Vice President of Corporate Finance and Business Development
AENZA S.A.A.
Av. Petit Thouars 4957
Miraflores
Lima 34, Peru
Re: AENZA S.A.A.
Form 20-F for the
Fiscal Year Ended December 31, 2021
Filed May 16, 2022
File No. 001-35991
Dear Fernando Rodrigo Baron:
We have reviewed your February 17, 2023 response to our comment
letter and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to the comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to the comment, we may have additional comments.
Fernando Rodrigo Baron
FirstName LastNameFernando Rodrigo Baron
AENZA S.A.A.
Comapany
April NameAENZA S.A.A.
5, 2023
April 25, 2023 Page 2
Page
FirstName LastName
Form 20-F for the Fiscal Year Ended December 31, 2021
Report of Independent Registered Public Accounting Firm, page F-2
1. We have reviewed your responses provided in response to our letters
dated December 1,
2022 and January 20, 2023 and continue to believe that the AENZA
S.A.A. financial
statements are materially deficient for any years that Vizcarra y
Asociados S.C.R.L. -
Moore Peru, a firm that is not registered with the Public Company
Accounting Oversight
Board ( PCAOB ), played a substantial role in the audit. Please
correct the material
deficiency in your audited financial statements to comply with Section
102(a) of the
Sarbanes-Oxley Act and PCAOB Rule 2100 that require any accounting
firm playing a
substantial role in the audit of an issuer be registered with the
PCAOB.
You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at
202-551-3295 if
you have questions.
Sincerely,
Division of
Corporation Finance
Office of Real
Estate & Construction
cc: Juan Mendez