SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

December 22, 2014

Via E-mail
Rick L. Weller
Chief  Financial Officer
Euronet Worldwide, Inc.
3500 College Blvd.
Leawood, KS 66211

 Re: Euornet Worldwide , Inc.
  Form 10-K for the Fiscal Year Ended December 31, 2013
  Filed February 27 , 2014
  File No. 1-31648

Dear M r. Weller :

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 preclude further review by the Assistant Director group with respect
to other issues.   In our comments, we ask  you to provide us with information so we may better
understand your discl osure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, please tell us  why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. In your letter to us dated December 22, 2011, you discussed contacts with Sudan, and
customers who have contacts  with Syria and Sudan.  As you are aware, Sudan and
Syria are designated by the State Department as state sponsors of terrorism, and are
subject to U.S. economic sanctions and export controls.  You do not provide
disclosure about these countries in the For m 10 -K.  Please describe to us the nature
and extent of your past, current, and anticipated contacts with Sudan and Syria since
your 2011 letter, whether through subsidiaries, affiliates, customers, or other direct or
indirect arrangements.  For instance , we are aware of a 2014 news article reporting
that you provide services to Standard Chartered Bank and UniCredit Group.  Recent
news articles report that these companies may have or have had contacts with Sudan
and Syria.  You should describe any products, services or technology provided to or

Rick L. Weller
Euronet Worldwide, Inc.
December 22, 2014
Page 2

 with respect to Sudan and Syria, directly or indirectly, and any agreements,
commercial arrangements, or other contacts with the governments of those countries
or entities they control.

2. Please discuss the materiality  of any contacts with Sudan and Syria you describe in
response to the comment above, and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in
quantitative terms, including the approximate dollar amounts of any associated
revenues, assets, and liabilities for the last three fiscal years and the subsequent
interim period .  Also, address materiality in terms of qua litative factors that a
reasonable investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a company’s reputation
and share value.  As you know, various state and municipal governments,
universities, and other investors have proposed or adopted divestment or similar
initiatives regarding investment in companies that do business with U.S. -designated
state sponsors of terrorism.  You should address the potential impact of the investor
sentime nt evidenced by such actions directed toward companies that have operations
associated with Sudan and Syria.

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 i nformation the Securities Exchange Act of
1934 and all applicable Exchange 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 adequacy of t he disclosures they have made.

In responding to our comments, 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 comments as a defense in any proceeding initiated by
the Commission or any person under the  federal securities laws of the United States.

Rick L. Weller
Euronet Worldwide, Inc.
December 22, 2014
Page 3

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

                  Sincerely,

                  /s/ Cecilia Blye

                  Cecilia Blye, Chief
                  Office of Global Security Risk

cc:  Jeffrey B. Newman
  Executive Vice President and General Counsel
  Euronet Worldwide, Inc.

  Todd Schiffman
  Assistant Director
 Division of Corporation Finance