World Acceptance Corporation ("WAC"), headquartered in South Carolina, was a consumer loan company whose common stock was registered with the SEC and traded on the Nasdaq. At the time of the misconduct, WAC operated in Mexico through its wholly-owned subsidiary, WAC de Mexico, S.A. de C.V. WAC sold WAC de Mexico on July 1, 2018, and currently does not have any foreign subsidiaries or conduct any business internationally.
According to the documents in this case, between December 2010 and June 2017, WAC de Mexico paid approximately $4.1 million in bribes, directly or through intermediaries, to Mexican government officials and union officials to obtain and retain business with the company's Prestamos Viva business line, which offered small loans to state and federal government employees. The bribes were inaccurately recorded as legitimate “commission” expenses in WAC’s books and records, and WAC failed to implement sufficient internal accounting controls over vendor management and accounts payable at WAC de Mexico, failed to provide reasonable assurances that WAC de Mexico had implemented an FCPA policy and was adhering to it, failed to provide FCPA training at WAC and WAC de Mexico, and lacked sufficient entity level controls over WAC de Mexico. In all, WAC made approximately $18 million on the bribery scheme.
In a settled administrative proceeding initiated on August 6, 2020, the SEC ordered WAC to cease and desist violation of the anti-bribery, books and records, and internal controls provisions of the FCPA. Under the terms of the agreement, WAC agreed to pay disgorgement of $17,826,000, prejudgment interest of $1,900,000, and civil penalties of $2,000,000, for a total payment of $21,726,000. The SEC noted WAC's cooperation in the investigation and remedial measures undertaken by the company.
