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Abstract: 

In this article the author addresses the SEC’s enforcement action against WAC for large scale bribery in its Mexican subsidiary. He finds the case of particular interest because the business model itself was high risk, red flags were ignored, and union and government officials were joined in the misconduct. It also highlights the new requirements in Latin America for companies to have compliance programs and, as part of such programs, to conduct third-party due diligence.

Keywords: World Acceptance Corporation

Affiliations:  1: Squire Patton Boggs.