Mail Stop 4628
                                                             August 1, 2018


Via Email
Mr. Soren Schroder, Chief Executive Officer
Bunge Limited
50 Main Street, 6th Floor
White Plains, NY 10606

       Re:    Bunge Limited
              Form 10-K for the Fiscal Year ended December 31, 2017
              Filed February 23, 2018
              Form 10-Q for the Fiscal Quarter ended March 31, 2018
              Filed May 2, 2018
              File No. 001-16625

Dear Mr. Schroder:

       We have reviewed your filings and have the following 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 these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2018

General

1.     In a letter to the staff dated January 14, 2016, you discussed your sale
of agricultural
       commodities and products to counterparties located in or exporting to
Sudan and
       Syria. Additionally, we are aware of a third-party website that
identifies you as a
       fertilizer company "serving" North Korea, Sudan and Syria.

       North Korea, Sudan and Syria are designated by the Department of State
as state
       sponsors of terrorism, and are subject to U.S. economic sanctions and/or
export
       controls. Please describe to us the nature and extent of any past,
current, and anticipated
       contacts with North Korea, Sudan and Syria since your 2016 letter,
including contacts
       with their governments, whether through subsidiaries, affiliates,
distributors, partners,
 Soren Schroder
Bunge Limited
August 1, 2018
Page 2

       resellers, customers, joint ventures or other direct or indirect
arrangements. Please also
       discuss the materiality of those contacts, in quantitative terms and in
terms of qualitative
       factors that a reasonable investor would deem important in making an
investment
       decision. Tell us the approximate dollar amounts of revenues, assets and
liabilities
       associated with those countries for the last three fiscal years and the
subsequent interim
       period. Address for us the potential impact of the investor sentiment
evidenced by
       divestment and similar initiatives that have been directed toward
companies that have
       operations associated with U.S.-designated state sponsors of terrorism.

Form 10-Q for the Fiscal Quarter ended March 31, 2018

Financial Statements

Note 2   Accounting Pronouncements, page 8

2.     We note that disclosures on pages three through eight of your annual
report indicate you
       engage in a wide range of revenue generating activities. However, we do
not see in your
       subsequent interim report many of the disclosures that are typically
required upon the
       adoption of FASB ASC 606, pertaining to the nature, amount, timing, and
uncertainty of
       revenue and cash flows arising from contracts with customers.

       Please address the following points.

                 Tell us the amounts of revenue recognized from contracts with
customers for each
                 period or confirm if the amounts are as depicted in your
tabulation on page 29.

                 With regard to the amounts attributable to revenues from
arrangements that you
                 believe are not within the scope of FASB ASC 606, describe the
underlying
                 transactions and identify the particular accounting guidance
that you apply to
                 those arrangements, along with your rationale. Tell us the
amounts applicable to
                 each type or category of such arrangements, disaggregated as
necessary and
                 reconciled to the amounts shown for each segment and on a
consolidated basis.

                 Please address each of the disclosure requirements in FASB ASC
606-10-50-1
                 through 23, as these pertain to your contracts with customers.
Identify any
                 specific disclosures in your interim report that you believe
are responsive to these
                 requirements. For example, these would generally entail
disclosures

                 (i)    indicating how the nature, amount, timing and
uncertainty of revenues and
                        cash flows associated with different types of contracts
with customers are
                        affected by economic factors;

                 (ii)   regarding the nature of goods or services that are
associated with the
                        performance obligations under your contracts with
customers, also
 Soren Schroder
Bunge Limited
August 1, 2018
Page 3

                         encompassing the timing of fulfillment, significant
payment terms, and
                         any residual obligations or warranties; and

                 (iii)   describing the judgements involved in determining when
performance
                         obligations have been satisfied, including recognition
methodology and
                         rationale, assessing when customers obtain control of
the promised goods
                         or services, and in determining the transaction price
and allocations of
                         transaction price to multiple performance obligations.

                 To the extent that you believe any of the specific
requirements are not applicable
                 or not material to your contracts with customers, provide an
explanation and
                 support for your view.

        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. You may contact Joseph Klinko at (202) 551-3824, John
Cannarella at (202)
551-3337 or me at (202) 551-3686 with any questions.

                                                              Sincerely,

                                                              /s/ Karl Hiller

                                                              Karl Hiller
                                                              Branch Chief
                                                              Office of Natural
Resources
