What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-01-26 compared with 2024-03-28 · 50 added, 41 removed, 4 unchanged (96% of the section changed)

UNRESOLVED STAFF COMMENTS

Not applicable.

Cybersecurity

Risk Management and Strategy

We identify and assess

material risks from cybersecurity threats to our information systems and the information residing in our information systems by monitoring

and evaluating our threat environment on an ongoing basis using various methods including, for example, using manual and automated tools,

subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat actors, conducting scans

of the threat environment, and conducting risk assessments.

We manage material risks

from cybersecurity threats to our information systems and the information residing in our information systems through various processes

and procedures, including, depending on the environment, risk assessments, incident detection and response, vulnerability management,

disaster recovery and business continuity plans, internal controls within our accounting and financial reporting functions, encryption

of data, network security controls, access controls, physical security, asset management, systems monitoring, and employee training.

We engage third-party service providers to provide some of the resources used in our information systems and some third-party service

providers have access to information residing in our information systems.

With respect to such third parties, we seek to engage reliable,

reputable service providers that maintain cybersecurity programs.

Depending on the nature and extent of the services provided, the sensitivity

and quantity of information processed, and the identity of the service provider, our processes may include conducting due diligence on

the cybersecurity practices of such provider and contractually imposing cybersecurity related obligations on the provider.

We are not aware of

any risks from cybersecurity threats, including as a result of any cybersecurity incidents, which have materially affected or are reasonably

likely to materially affect AGBA, including our business strategy, results of operations, or financial condition.

Refer to “Part

I, Item 1A—Risk Factors—Risks Factor Relating to AGBA’s business—Unexpected network interruptions, security breaches,

cyberattack or computer virus attacks, and failures in AGBA’s information technology systems, could have a material adverse effect

on AGBA’s business, financial condition, and results of operations” in this Form 10-K for additional discussion about cybersecurity-related

Risk Management

identify and assess material risks from cybersecurity threats to our information systems and the information residing in our information

systems by monitoring and evaluating our threat environment on an ongoing basis using various methods including, for example, using manual

and automated tools, subscribing to reports and services that identify cybersecurity threats, analyzing reports of threats and threat

actors, conducting scans of the threat environment, and conducting risk assessments.

manage material risks from cybersecurity threats to our information systems and the information residing in our information systems through

various processes and procedures, including, depending on the environment, risk assessments, incident detection and response, vulnerability

management, disaster recovery and business continuity plans, internal controls within our accounting and financial reporting functions,

encryption of data, network security controls, access controls, physical security, asset management, systems monitoring, and employee

We engage third-party service providers to provide some of the resources used in our information systems and some third-party

service providers have access to information residing in our information systems.

With respect to such third parties, we seek to engage

reliable, reputable service providers that maintain cybersecurity programs.

Depending on the nature and extent of the services provided,

the sensitivity and quantity of information processed, and the identity of the service provider, our processes may include conducting

due diligence on the cybersecurity practices of such provider and contractually imposing cybersecurity related obligations on the provider.

development and operation of Triller’s Technology Platform is subject to physical, technological, security and other risks which

may result in interruption in service or reduced capacity.

These risks include physical damage, power loss, telecommunications failure,

capacity limitation, hardware or software failures or defects and breaches of physical and cybersecurity by computer viruses, system break-ins or

An increase in the volume of usage of Triller’s Technology Platform could strain the capacity of the software and hardware

employed to prevent and identify such failures, breaches and attacks, which could result in slower response time or system failures.

In particular, Triller’s industry has witnessed an increase in the number, intensity and sophistication of cybersecurity incidents

caused by hackers and other malicious actors such as foreign governments, criminals, hacktivists, terrorists and insider threats.

and other malicious actors may be able to penetrate Triller’s network security and misappropriate or compromise Triller’s

confidential, sensitive, personal or proprietary information, or that of third parties, and engage in the unauthorized use or dissemination

of such information.

They may be able to create system disruptions, or cause shutdowns.

Hackers and other malicious actors may be able

to develop and deploy viruses, worms, ransomware and other malicious software programs that attack Triller’s products or otherwise

exploit any security vulnerabilities of Triller’s systems.

In addition, sophisticated hardware and operating system software

and applications that Triller procures from third parties may contain defects in design or manufacture, including “bugs,”

cybersecurity vulnerabilities and other problems that could unexpectedly interfere with the operation or security of its systems.

example, in 2022, as a result of a bug introduced in the application, Triller estimated that potentially 504 accounts may have been compromised.

Cybersecurity

Our Board of Directors

holds oversight responsibility over AGBA’s risk management and strategy, including material risks related to cybersecurity threats.

Board of Directors holds oversight responsibility over Triller’s risk management and strategy, including material risks related

to cybersecurity threats.

This oversight is executed directly by our board of directors and through its committees.

Our audit committee oversees the management

of AGBA’s major financial risk exposures, the steps management has taken to monitor and control such exposures, and the process

by which risk assessment and management is undertaken and handled, which would include cybersecurity risks, in accordance with its charter.

The audit committee holds regular meetings and receives periodic reports from management regarding risk management, including major financial

risk exposures from cybersecurity threats or incidents.

Within management, the

Group Chief Information Officer of our business units are primarily responsible for assessing and managing our material risks from cybersecurity

threats on a day-to-day basis and keep the senior executive officers informed on a regular basis of the identification, assessment, and

management of cybersecurity risks and of any cybersecurity incidents.

Such management personnel have prior experience and training in

managing information systems and cybersecurity matters and participate in ongoing training programs.

As of the date hereof, the Company has not

encountered cybersecurity incidents that the Company believes to have been material to the Company taken as a whole.

Our audit committee

oversees the management of Triller’s major financial risk exposures, the steps management has taken to monitor and control such

exposures, and the process by which risk assessment and management is undertaken and handled, which would include cybersecurity risks,

in accordance with its charter.

The audit committee holds regular meetings and receives periodic reports from management regarding risk

management, including major financial risk exposures from cybersecurity threats or incidents.

management, the Group Chief Information Officer of our business units are primarily responsible for assessing and managing our material

risks from cybersecurity threats on a day-to-day basis and keep the senior executive officers informed on a regular basis of the identification,

assessment, and management of cybersecurity risks and of any cybersecurity incidents.

Such management personnel have prior experience

and training in managing information systems and cybersecurity matters and participate in ongoing training programs.

of the date hereof, the Company has not encountered cybersecurity incidents that the Company believes to have been material to the Company

taken as a whole.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments