Exhibit 31.2

                                  CERTIFICATION
                          PURSUANT TO 17 CFR 240.13a-14
                                PROMULGATED UNDER
                  SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002


I, David P. Luci, certify that:

1.       I have reviewed this annual report on Form 10-KSB of Bioenvision, Inc.;

2.       Based on my knowledge, this annual report does not contain any untrue
         statement of a material fact or omit to state a material fact necessary
         to make the statements made, in light of the circumstances under which
         such statements were made, not misleading with respect to the period
         covered by this annual report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this annual report, fairly present in all
         material respects the financial condition, results of operations and
         cash flows of the registrant as of, and for, the periods presented in
         this annual report;

4.       The registrant's other certifying officer and I am responsible for
         establishing and maintaining disclosure controls and procedures (as
         defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) for the
         registrant and have:

         (a)  Designed such disclosure controls and procedures, or caused such
              disclosure controls and procedures to be designed under our
              supervision, to ensure that material information relating to the
              registrant, including its consolidated subsidiaries, is made known
              to us by others within those entities, particularly during the
              period in which this annual report is being prepared;
         (b)  Evaluated the effectiveness of the registrant's disclosure
              controls and procedures and presented in this annual report our
              conclusions about the effectiveness of the disclosure controls and
              procedures, as of the end of the period covered by this annual
              report based on such evaluation; and

         (c)  Disclosed in this report any change in the registrant's internal
              control over financial reporting (as defined in Exchange Act Rules
              13a-15(f) and 15d-15(f)) that occurred during the registrant's
              most recent fiscal quarter (the registrant's fourth fiscal quarter
              in the case of an annual report) that has materially affected, or
              is reasonably likely to materially affect, the registrant's
              internal control over financial reporting;

   5.    The registrant's other certifying officer and I have disclosed, based
         on our most recent evaluation of internal control over financial
         reporting, to the registrant's auditors and the audit committee of

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         registrant's board of directors (or persons performing the equivalent
         function):

         (a)  All significant deficiencies and material weaknesses in the design
              or operation of internal control over financial reporting which
              are reasonably likely to adversely affect the registrant's ability
              to record, process, summarize and report financial information;
              and

         (b)  Any fraud, whether or not material, that involves management or
              other employees who have a significant role in the registrant's
              internal control over financial reporting.



Date: September 24, 2004

                                      /s/ David P. Luci
                                     --------------------------
                                     David P. Luci
                                     Principal Financial and Accounting Officer