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;

5.       The  registrant's  other  certifying  officer and I are 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;

     4.  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
         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 29, 2003

                                                        /s/ David P. Luci
                                                      --------------------------
                                                      David P. Luci
                                                      Chief Accounting Officer