SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE

December 13, 2011
Via E-Mail
Michael J. Brown
Chairman and Chief Executive Officer Euronet Worldwide, Inc. 3500 College Boulevard Leawood, KS 66211

 Re: Euronet Worldwide, Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2010   Filed February 25, 2011   File No. 1-31648
Dear Mr. Brown:

We have limited our review of your filing 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 precl ude further review by
the Assistant Director group w ith respect to other issues.   At this juncture, we are
asking you to provide us with informa tion so we may better understand your
disclosure.
Please respond to this letter within te n business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not believe our comment applie s to your facts and circumstances, please tell us why in
your response.
 After reviewing the information you provide in response to this comment, we may
have additional comments.  General

1. Please update us on any contacts with Iran, Syria and Sudan since your letter to us
of October 9, 2008, including any indirect  contacts through services provided by
Al Salam Bank.  As you know, Iran, Syria and Sudan are iden tified by the State
Department as a state sponsor of terr orism and are subject to U.S. economic
sanctions and export controls.
Please describe to us the nature and exte nt of any past, current, and anticipated
contacts with Iran, Syria and Sudan whether through affiliates, subsidiaries, or other direct or indi rect arrangements.  In this re gard, we note a 2007 news article

Michael J. Brown
Euronet Worldwide, Inc. December 13, 2011 Page 2
 reporting that Euronet Middle East has a multiyear agreement with Arab Banking
Corporation to drive its ATMs and debit ca rds management in all countries where
it has retail operations.   According to Arab Banking Corporation’s website, it has
a representative office in Iran and it has cl ients in Iran; and according to public
websites and news articles, Arab Banki ng Corp. conducts business in Syria and
Sudan.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exch ange Act rules require.  Since the company
and its management are in possession of all facts relating to the company’s disclosure,
they are responsible for the accuracy and adequa cy of the disclosures they have made.
 In responding to our comment, please provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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.

Please contact Jennifer Hardy, Special C ounsel, at (202) 551- 3767 or me at (202)
551-3470 if you have any questions about  the comment or our review.

        S i n c e r e l y ,

        /s/ Cecilia Blye          C e c i l i a  B l y e ,  C h i e f          Office of Global Security Risk   cc:  Todd Schiffman   Assistant Director  Division of Cor poration Finance