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Issues To Consider From The World Acceptance Corp. Enforcement Action

Issues

This prior post went in-depth into the SEC’s recent $21.7 million Foreign Corrupt Practices Act enforcement action against World Acceptance Corp. (WAC) and this post highlights additional issues to consider.

Timeline

As highlighted in this post, WAC disclosed its FCPA scrutiny in mid-2017.  Thus, from start to finish, its scrutiny lasted more than three years. I’ve said it many times, and will continue saying it until the cows come home, if the SEC wants its FCPA enforcement program to be viewed as credible and effective it must resolve instances of FCPA scrutiny much quicker.

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World Acceptance Corp. Resolves $21.7 Million Enforcement Action Based On The Conduct Of A Former Wholly-Owned Mexico Subsidiary

world accept

As highlighted in this prior post, in June 2017 World Acceptance Corporation (a South Carolina based consumer finance company) disclosed that it was “conducting an internal investigation of its operations in Mexico, focusing on the legality under the U.S. Foreign Corrupt Practices Act and certain local laws of certain payments related to loans, the maintenance of the Company’s books and records associated with such payments, and the treatment of compensation matters for certain employees.”

As highlighted in this prior post, in May 2020 the company disclosed that “discussions with the SEC have progressed to a point that the Company can now reasonably estimate a probable loss and has recorded an aggregate accrual of $21.7 million with respect to the SEC matters.”

Yesterday, the SEC announced that World Acceptance Corp. agreed to resolve a $21.7 million FCPA enforcement action based on the actions of a former wholly-owned Mexican subsidiary it sold in July 2018.

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Scrutiny Alerts And Updates

scrutiny alert

This post highlights a new instance of Foreign Corrupt Practices Act scrutiny involving KT Corporation (a South Korean telephone company) and updates regarding long-standing FCPA scrutiny of Herbalife, World Acceptance Corp., Raytheon, and Stericyle.

KT Corporation

For several years, KT Corp (South Korea’s largest telecom company with shares traded on the New York Stock Exchange) has been under scrutiny by South Korean authorities for, among other things: donations to non-profit foundations at former President Park’s request; making certain donations or gifts to various lawmakers; and alleged improper hiring of college graduates.

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Friday Roundup

Roundup

Quotable, sentenced, scrutiny updates, dismissed and for the reading stack. It’s all here in the Friday roundup.

Quotable

In a recent Corporate Crime Reporter interview, former DOJ FCPA prosecutor Ephraim Wernick was asked if FCPA enforcement has changed under the Trump administration and stated:

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Friday Roundup

Roundup

Good lord, scrutiny alert and updates, across the pond, and for the reading stack. It’s all here in the Friday roundup.

Good Lord

Here is how Rep. Jackie Speier (an individual with a law degree) described the Foreign Corrupt Practices Act on a recent CNN program – “It is a requirement that anyone doing business with a foreign entity make sure that none of the money that comes into a project has been laundered.”

Good lord, get it right or stop talking about the FCPA.

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