Blockchain Week in Review - March 2019 #3

by Perkins Coie
Contact

[author: Paul Ford]

U.S. Developments

Regulatory Updates

SEC Chairman Clayton Explains that an Asset Can Lose Its Status of Being Labeled a Security

U.S. Securities and Exchange Commission (“SEC”) Chairman Jay Clayton appears to have confirmed SEC-staff analysis of the classification of decentralized digital assets.  Last year, SEC Director of Corporation Finance William Hinman said during a speech that decentralization impacts the classification of digital assets and that, by way of example, Ethereum did not exhibit the properties of a security. Congressman Ted Budd, along with the industry advocacy group Coin Center, wrote a letter to Chairman Clayton asking for clarification on whether the Chairman agreed. 

In Chairman Clayton’s response to the letter, he agrees with Director Hinman’s explanation that “the analysis of whether a digital asset is offered or sold as a security is not static and does not strictly inhere to the instrument.”  The Chairman goes on to explain that if “purchasers would no longer reasonably expect a person or group to carry out the essential managerial or entrepreneurial efforts . . . the digital asset may not represent an investment contract under the Howey framework.”

CFTC’s Nearly $1 million Consent Order Against 1pool Ltd.

The Commodity Futures Trading Commission (“CFTC”) entered a Consent Order (“Order”) resolving a CFTC action against 1pool Ltd., a limited liability company located in the Marshall Islands, and its Chief Executive Officer and owner, Patrick Brunner.  The defendants were alleged to have violated multiple laws in their operation of an online trading platform, www.1broker.com, that offered customers retail commodity transactions, among other products.  In total, the defendants are paying $990,000 in resolution of the CFTC action.  The defendants were subject to a civil monetary penalty and disgorgement of gains and were required to pay all known U.S. customers the bitcoin amount held by the defendants in U.S. customers’ accounts via the online trading platform.

According to the CFTC, the defendants violated laws through the trading platform by illegally offering retail commodity transactions that were margined in bitcoin, failing to register as a futures commission merchant with the CFTC, and failing to meet supervisory duties by not implementing adequate anti-money laundering procedures.  Notably, the CFTC viewed Brunner, as the developer of the trading platform and 1pool Ltd.’s chief executive officer, sole shareholder and beneficial owner, as having the requisite degree of control, whether direct or indirect, over the platform’s operations and its accessibility by U.S. persons to justify a finding that Brunner should also be personally liable for the violations.

In reference to the Order, James McDonald, the CFTC Director of Enforcement, stated: “Intermediaries should take notice that they will be held accountable by the CFTC for failing to comply with registration requirements and failing to implement policies and procedures that are crucial in protecting U.S. customers and our markets.  Through the Division’s Bank Secrecy Task Force, Enforcement will continue to investigate and prosecute such violations.”

A copy of the Order can be found here.

SEC Welcomes Public Input on Non-DVP Custodial Practices and Digital Assets: Investment Advisers Act of 1940: Rule 206(4)-2

Back in February 2017, the SEC Division of Investment Management (the “Division”) issued Guidance Update 2017-01, which discussed the Custody Rule under the Investment Advisers Act of 1940 (“Advisers Act”).  Since the issuance of that Guidance Update, investment advisers and other market participants have raised issues regarding the regulatory status of investment adviser and custodial trading practices that are not processed or settled on a delivery versus payment (“Non-DVP”) basis, which is explained in more detail below.  The Division is now welcoming engagement from advisers, other market participants, and the public on such issues and on the applicability of the Custody Rule to digital assets.

The Custody Rule is a key investor protection under the Advisers Act that prohibits an investment adviser that is registered or required to be registered under the Advisers Act to have “custody” of client funds or securities unless such funds are maintained in accordance with the requirements of the Custody Rule.  “Custody,” per the Advisers Act, includes “[a]ny arrangement (including a general power of attorney) under which [an investment adviser is] authorized or permitted to withdraw client funds or securities maintained with a custodian upon [the investment adviser’s] instruction to the custodian.”  Authority over and access to client securities and funds fall within the definition of custody as well.

The Division has explained that the Custody Rule does not apply to authorized trading because clients’ custodians are generally under instructions to transfer funds (or securities) out of a client’s account only upon corresponding transfer of securities (or funds) into the account.  The Division finds that this “‘delivery versus payment’ arrangement minimizes the risk that an [investment] adviser could withdraw or misappropriate the funds or securities in its client’s custodial account.”

However, concern about the risks of misappropriation inherent in Non-DVP arrangements still exists.  Where trading or settlement payment precedes delivery, there is a heightened risk that an investment adviser could misappropriate funds or securities in its client’s custodial account.  In alignment with such concern, the Division has noted that even a moment’s custody of client assets puts those assets at risk of misuse or loss.  As the digital currency sector expands, this concern has become pervasive.

Apart from the Custody Rule, investment advisers have an obligation to safeguard clients’ assets, and registered investment advisers, specifically, have an obligation to review internal controls to reduce the risk of misappropriation or loss per Rule 206(4)-7 of the Advisers Act.  Nonetheless, the Division welcomes engagement from advisers, other market participants, and the public on policy recommendations to better protect assets via the Advisers Act and especially the Custody Rule.

Industry Updates

Mark Karpeles Verdict

The Tokyo District Court has found Mark Karpeles, the former CEO of one of the largest bitcoin exchanges at the time, guilty of tampering with exchange data related to Mt. Gox.  The court, however, rejected charges of embezzlement and breach of trust despite allegations that Karpeles misappropriated about $3 million of customers’ funds for his own personal use.  The court rejected these charges because it concluded that Karpeles had acted without ill intent.

In December 2018 Japanese prosecutors were seeking a 10-year jail sentence.  Instead, Karpeles was handed a suspended sentence of two years and six months.  He must maintain a good record over the next four years to avoid jail time.

State Updates

Texas Proposes Bill that Would Require the Disclosure of the True Identities of Parties in Cryptocurrency Transactions: H.B. No. 4371.

If enacted, Texas House Bill Number 4371 (“H.B. No. 4371”) will require Texas citizens involved in digital currency transactions to verify the identity of the opposing party to the digital currency transaction.  The bill also bans the State of Texas from using digital currency that is not a verified identity digital currency.  A “verified identity digital currency” is a digital currency that allows the true identities of the sender and receiver to be known before a person has access to another person’s digital wallet.

The bill does not appear to require that persons retain the identity information that they are forced to “verify,” nor does it say that this identity information shall be available to law enforcement without a warrant.  H.B. No. 4371 has attracted an abundance of criticism because many critics find the proposed language to be confusing and a clear indicia of a misunderstanding of the fundamentals of cryptocurrency and the mechanics of a cryptocurrency transaction.

The bill has not been voted on, but if passed, the bill will take effect later this year: September 1, 2019.

Colorado Provides a State-Licensing Exemption in “Colorado Digital Token Act” for Cryptocurrency Created for a “Consumptive Purpose”

Colorado’s Senate Bill 19-023 (the “Colorado Digital Token Act”) has passed and is set to take effect on August 2, 2019.

The Colorado Digital Token Act fortifies Colorado’s status as a cryptocurrency-friendly state.  The bill directly acknowledges the importance of cryptocurrency as well as the constricting regulatory regime of the space.  The bill furthermore establishes Colorado as a breeding ground for cryptocurrency businesses by providing a licensing exemption for a person engaged in the business of effecting or attempting to effect the purchase, sale, or transfer of a digital token if the token was created for a “consumptive purpose.”  A “consumptive purpose” includes “to provide or receive goods, services, or content, including access to goods, services, or content.”

The Colorado Digital Token Act declares that its enactment “will enable Colorado businesses that use cryptoeconomic systems to obtain growth capital to help grow and expand their businesses, thereby promoting the formation and growth of local companies and the accompanying job creation and helping make Colorado a hub for companies that are building new forms of decentralized ‘Web 3.0’ platforms and applications.”

International Developments

Amendment to Cayman Islands’ Proceeds of Crime Law (2019 Revision) Expands Regulatory and Reporting Obligations

The Cayman Islands Proceeds of Crime (Amendment) Bill, 2019 would amend the Proceeds of Crime Law (2019 Revision) by broadening the powers and duties of the country’s regulatory authorities over financial due diligence and governance, including the Financial Reporting Authority and the Anti-Money Laundering Steering Group.  The bill also lessens the burden for a person to be found guilty of “tipping off” wrongdoers that a report (similar to a Suspicious Activity Report) is made or is likely to be made, while providing a safe harbor for those who disclose information in pursuit of mandated legal disclosures.

Additionally, the bill would include the activities of a “virtual asset service” as a “relevant financial business”; entities that are relevant financial businesses under Cayman law have regulatory and reporting obligations.  The bill defines a “virtual asset” as a “digital representation of value that can be digitally traded or transferred, and can be used for payment or investment purposes.”

FinCEN and the FATF Warn of AML/CFT Deficiencies of the Democratic People’s Republic of Korea and Iran; Cambodia Is Added to FATF List

As part of a continued global effort to protect financial institutions and combat the financing of criminal activity, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory to inform financial institutions of updates to the Financial Action Task Force (the “FATF”) list of countries and jurisdictions with strategic anti-money laundering and combatting the financing of terrorism (“AML/CFT”) deficiencies.  The Democratic People’s Republic of Korea (“DPRK”) and Iran were specifically highlighted given that they are subject to a call for action, effectively meaning that these jurisdictions are blacklisted.  Additionally, Cambodia was added to the FATF list of jurisdictions with strategic AML/CFT deficiencies.

The FATF renewed its call for institutions engaging with DPRK to impose counter-measures to mitigate the major deficiencies in the country’s financial system.  The FATF issued a public statement explaining that serious threats are posed to the integrity of the international financial system by the DPRK’s continued failure to address significant deficiencies in its AML/CFT regime.  The FATF noted that it was particularly concerned about the financing and proliferation of weapons of mass destruction.  FinCEN encourages institutions engaged with the DPRK  to apply safeguards in dealings with the DPRK that are in accordance with United Nations Security Council resolutions, such as prohibiting financial institutions from establishing new joint ventures with DPRK banks without advance approval from the UN, expelling individuals acting on behalf of a financial institution of the DPRK, and prohibiting public and private financial support and trade with the DPRK.

The FATF noted that Iran has not adequately criminalized terrorist financing and other terrorism activity and is not identifying and freezing terrorist assets.  The FATF indicated that a customer due diligence regime is still not properly implemented in Iran’s financial sector.  The FATF noted several other areas needing improvement with regard to governance and deterrence focused on terrorist activity.

The EU’s Second Payment Services Directive Testing Period

As the testing period begins for the European Union’s Second Payment Services Directive (“PSD2”), commentators are concerned about how to phase the PSD2 into transactions with financial instructions in a practical way.  The PSD2 is intended to result in a legal framework that enables enhanced consumer protection, promotes innovation, and improves the security of payments services.  Such precepts may possibly seem to clash with the requirements of online data privacy law promulgated by the General Data Protection Regulation (“GDPR”).  The testing period is intended to provide policy makers with greater insight into proper governance and implementation of the PSD2, especially in compliance with the GDPR.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Perkins Coie | Attorney Advertising

Written by:

Perkins Coie
Contact
more
less

Perkins Coie on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.