Abstract: Program translation takes a program written in some source language and creates an equivalent program in some target language. This process is very important in software maintenance, particularly when the source program is written in old language such as Cobol and Fortran. The goal of translation is efficiency and readability of the target program. In this study, we present a new approach to translate COBOL program via a dependence model in order to capture dependences between instructions. This model makes process of translation more adequate than the current approaches.