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			AXIS Capital Holdings Limited 29 Richmond Road, 3rd Flr Pembroke HM 08 Bermuda

February 27, 2026

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

Re:     Notice of disclosure filed in Annual 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 Annual Report on Form 10-K for the year ended December 31, 2025, which was filed with the Securities and Exchange Commission on February 27, 2026.

Respectfully submitted,

AXIS Capital Holdings Limited

By: /s/ Christina Gray-Trefry

Christina Gray-Trefry

General Counsel & Corporate Secretary