United States securities and exchange commission logo




                                                                                
                           January 20, 2023

       Fredy Chalco
       VP of Corporate Finance
       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 Fredy Chalco :

               We have reviewed your December 15, 2022 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. Unless we note otherwise, our reference to the prior comment 
is to the comment in
       our December 1, 2022 letter.

       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 
response to our comment 1 and acknowledge our phone
                                                        conversation with you 
and your former independent registered public accounting firm,
                                                        Moore Assurance S.A.S. 
(   Moore   ), on January 10, 2023. Please respond to the
                                                        following:
                                                            Describe the nature 
of the relationship between the audit firms of Moore and Vizcarra
                                                             y Asociados 
S.C.R.L. Moore Peru ("Moore Peru") as it pertains to the audit of your
                                                             consolidated 
financial statements for the three years ended December 31, 2021 and
                                                             underlying 
business reasons for structuring the audit in this manner.
                                                            Describe the nature 
and extent of supervision and direction by Moore to the Moore
 Fredy Chalco
AENZA S.A.A.
January 20, 2023
Page 2
          Peru employees that participated in the audits of the consolidated 
financial statements
          for the three years ended December 31, 2021. As part of your 
response, please
          discuss the PCAOB Standards applied in performing the audit in this 
manner.
            Describe how the employees and partners participating in the audits 
of your
          consolidated financial statements became employees of Moore Peru, and 
who was
          responsible for hiring of these employees. As part of your response, 
discuss where
          these partners and employees for your audit were sourced from and any 
business
          reasons for structuring the hiring in this manner.
            Explain in further detail how you and Moore concluded that the 
performance of the
          audits in this manner, which included Moore Peru, an unregistered 
firm, playing a
          substantial role in the audit of your consolidated financial 
statements for the three
          years ended December 31, 2021, did not violate PCAOB Rule 2100.

       You may contact Babette Cooper at 202-551-3396 or Jennifer Monick at 
202-551-3295 if
you have any questions.



                                                           Sincerely,
FirstName LastNameFredy Chalco
                                                           Division of 
Corporation Finance
Comapany NameAENZA S.A.A.
                                                           Office of Real 
Estate & Construction
January 20, 2023 Page 2
cc:       Juan Mendez
FirstName LastName