SecProbe.io

September 30, 2008

 Mail-Stop 5546    Mr. Michael J. Brown
Chief Executive Officer
Euronet Worldwide, Inc.   4601 College Boulevard Suite 300 Leawood, Kansas 66211   Re: Euronet Worldwide, Inc.  Form 10-K for Fiscal Year Ended December 31, 2007  File No. 1-31648   Dear Mr. Brown:
 We have limited our review of your filing referenced above, to disclosure
relating to your contacts with  countries that have been identified as state sponsors of
terrorism, and we have the following comments.  Our review with respect to this issue does not preclude further review by the Di vision of Corporation Finance’s assistant
director group to whom your company is assigne d with respect to other issues.  At this
juncture, we are asking you to provide us with supplemental information, so that we
may better understand your disclosure.  Please be as detailed as necessary in your response. After reviewing this information, we may raise additional comments.
The purpose of our review process is to assist you in your compliance with the
applicable disclosure requirements and to enhance the overall disclosure in your filings.  We look forward to working with you in th ese respects.  We welcome any questions you
may have about our comments or on any other as pect of our review.  Feel free to call us
at the telephone numbers listed at the end of this letter.

General

1. We note the references in your 10-K to the Middle East.  We also note that there
have been press stories reporting that Euronet Middle East entered into an
agreement with Al Salam Bank-Bahrain.  We also note in those reports that Al Salam Bank-Bahrain is partially owne d by Al Salam Bank-Sudan, a Sudanese

Mr. Michael J. Brown
Euronet Worldwide, Inc.
Page 2

2. company.  While your 10-K did not speci fically mention Iran, Syria or Sudan,
they are countries in that region and they ha ve been identified as state sponsors of
terrorism by the U.S. Department of St ate, and are subject to U.S. economic
sanctions and export controls.  Please de scribe for us any past, current, and
anticipated operations in, or other contacts with, Iran, Syria or Sudan.  Your
response should include descriptions of  contacts through subsidiaries, joint
ventures or distribut ors, or other indirect arrange ments, if any.  Describe in
reasonable detail the nature and scope of  any products, technologies, equipment,
and services you have provided in each of  the three countries, as well as any
agreements, commercial arrangements or other contacts with the government, or
entities controlled by the government , of any of the three countries .

3. Please discuss the materiality of any ope rations and other contacts described in
response to the foregoing comment, and wh ether they would constitute a material
investment risk for your security holde rs.  You should address materiality in
quantitative terms, including the approximate  dollar amounts of any associated
revenues, assets, and liabilities for the past three fis cal years.  Also, address
materiality in terms of qualitative factor s that a reasonable in vestor would deem
important in making an investment deci sion, including the potential impact of
corporate activities upon a company’s reputa tion and share value.  In this regard,
we note that various state and municipa l governments, universities, and other
investors have proposed or adopted divestment or ot her initiatives regarding
investment in companies that do business with state sponsors of terrorism.  Your
materiality analysis should address the potential impact of investor sentiment
directed toward companies that have busin ess contacts with countries identified as
state sponsors of terrorism.

 Closing Comments

  Please respond to these comments within  10 business days or tell us when you
will provide us with a re sponse.  Please submit your response letter on EDGAR.
  We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings to be certain that the filings include all information required under the Exchange Act of 1934 and that they  have provided all information investors
require for an informed investment decision.  Since the company and its management are
in possession of all facts rela ting to the company’s disclosure , they are responsible for the
accuracy and adequacy of the disclosures they have made.

Mr. Michael J. Brown
Euronet Worldwide, Inc.
Page 3

 In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filings;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filings; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.
  In addition, please be advise d that the Division of Enforcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.   Please understand that we may have addi tional comments after we review your
response to our comments.  Please contact William Friar (202) 551-3418 if you have any
questions about the comments or our review.  You may also contact me at (202) 551-3470.

      S i n c e r e l y ,           Cecilia Blye, Chief       Office of Global Security Risk    cc:  Todd Schiffman, SEC