July 17, 2024
Carlos Doglioli
Chief Financial Officer
ATN International, Inc.
500 Cummings Center, Suite 2450
Beverly, MA 01915
Re: ATN International, Inc.
Form 10-K for the fiscal year ended December 31, 2023
File No. 001-12593
Dear Carlos Doglioli:
We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this letter, we may have additional
comments.
Form 10-K for the fiscal year ended December 31, 2023
Item 9A. Controls and Procedures, page 59
1. You disclose that management assessed the effectiveness of your internal
control over
financial reporting as of December 31, 2023; however, you do not to
include a statement
as to whether or not internal control over financial reporting is
effective. Please amend
your filing to include this disclosure. Refer to Item 308(a)(3) of
Regulation S-K.
July 17, 2024
Page 2
In closing, 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.
Please contact Melissa Kindelan at 202-551-3564 or Christine Dietz at
202-551-3408
with any questions.
Sincerely,
Division of
Corporation Finance
Office of Technology