EU and UK Sanctions and Export Controls Update – Winter 2017

by K&L Gates LLP

K&L Gates LLP

The EU and UK sanctions regimes have seen significant change during the last few months. Discussions are ongoing regarding the UK's plans for its post-Brexit sanctions policy but uncertainty and division dominates the headlines. Outside of the UK, the world of sanctions is ever-changing, with the EU continuously reviewing and/or revising many of the sanctions it imposes on individuals, entities and governments. In addition, the past few months have seen the Trump administration undermine the Iran nuclear deal, the EU and UN expand sanctions imposed on North Korea, Lithuania introduce its own Magnitsky Act and French authorities carry out a dawn raid against LafargeHolcim for alleged terrorist financing. Below is a summary of some of the main updates since our last alert (see here) for sanctions and export controls across the UK and EU.

UK Updates

The Sanctions and Anti-Money Laundering Bill
Since our last update, the Government's plans for the UK's post-Brexit sanctions policy have come under significant scrutiny in various sub-committee meetings and reports, including a review of the new Sanctions and Anti-Money Laundering Bill (the "Sanctions Bill"), the text of which was published on the 19 October 2017.

The Sanctions Bill introduces the framework through which the UK will be able to legislate to impose sanctions once it has left the EU. It allows the UK Government to impose sanctions through secondary legislation, without the approval of Parliament, as well as issue licences to permit sanctioned conduct. However, it is worth noting that the UN currently influences a large proportion of the EU's and UK's sanctions policy and, pursuant to the UK's continued membership of the UN, will carry on doing so post-Brexit.

In addition, the current version of the Sanctions Bill extends the obligation to report sanctioned entities (addressed in our last update) to all legal persons, for which a failure to comply is a criminal offence. If this provision remains, it will increase the burden of compliance for businesses, which will need to address their sanctions escalation processes.

Since the text of the Bill was published, the House of Lords Select Committee on the Constitution has criticised the broad powers granted to the ministers to create new sanctions, calling them "constitutionally inappropriate". It also raised concerns about the ability of ministers to create criminal offences under those same powers. Among others, Lord Pannick QC called for reform of the Sanctions Bill, so that ministers are required to consider necessity and proportionality when imposing new sanctions.

Furthermore, the Joint Committee on Human Rights, in its review of the Bill, has raised concerns about the extent of the delegated powers given to the Government to impose sanctions, as well as the level of safeguards required to ensure the Bill complies with human rights requirements, pointing to a lack of parliamentary scrutiny of measures that can result in criminal offences and a loss of liberty. As such, the committee has called for much of the detail that has been left to be defined in the regulations imposed under the Government's delegated powers to instead be included in the Bill itself.

It is expected that the Sanctions Bill will receive royal asset in April 2019.

Future relationship between the UK and EU sanctions policies
On 17 December 2017, the House of Lords EU External Affairs Sub-Committee published a report, setting out its views on the UK's post-Brexit sanctions policy, in which it suggested that the UK should continue to co-ordinate closely on sanctions policy with the EU. The Sub-Committee has recommended that if the UK is unable to continue to participate in a common foreign and security policy with the EU, then the Government ought to propose that a political forum be established between the EU and the UK to coordinate sanctions policy and at the very least, have an informal engagement with the EU on sanctions, similar to the current relationship the EU has with the US. As the UK and EU enter the second stage of negotiations, we will continue to update you on any developments.

Office of Financial Sanctions Implementation guidance for charities and non-government organisations
In reaction to several requests from small charities for clearer information on issues affecting the sector, so that they could ensure compliance, the Office of Financial Sanctions Implementation has provided a factsheet for charities and other non-government organisations that provides guidance on operating in areas where financial sanctions are in force. The guidance addresses issues such as accepting donations from, or giving donations to, individuals and entities in countries subject to sanctions, the licensing regime in relation to financial sanctions and how to deal with financial services organisations.

Export controls update
In late November 2017, the Export Control Organisation announced that it had updated nine UK open general export licences ("OGELs"), which are pre-published licences to export certain goods on specified terms. The OGELs were updated in light of amendments made by the EU to its control list of dual-use items, the majority of which were agreed under a multilateral export control regime also known as the Wassenaar Arrangement. The 41 participating members of the Wassenaar Arrangement introduced a number of technical changes that are reflected in the updates to the OGELs. In addition, the updated OGELs put in place a number of new controls, for instance two new sub-entry controls for plasma torches and electron beam guns were introduced. These changes came into force on 16 December 2017.

EU Jurisdictional Update

Lithuania & the Magnitsky Act
On 16 November 2017, the Lithuanian Parliament unanimously passed legislation that allows for sanctions to be imposed against individuals suspected of human rights violations. The legislation is a version of the Magnitsky Act, a law originally passed by the United States under the Obama administration to sanction Russian officials responsible for human rights abuses that led to the death of Russian accountant, Sergei Magnitsky. This law was then extended to cover all human rights abuses across the globe, not just in Russia. Lithuania was the fifth state to pass Magnitsky sanctions laws, with Canada, Estonia and the UK also having introduced similar legislation in the past.

In November last year, the EU Council imposed an arms and dual-use goods embargo, as well as a prohibition on the export of equipment, technology or software intended primarily for the use of surveillance of telecommunications or internet-based communications. These sanctions were imposed on the Venezuelan government for alleged corruption of its current leader, President Maduro and are, in part, a reaction to the UN report that states that there are extensive human rights violations and abuses being carried out by the current government.

In addition, the EU has established a framework to impose financial sanctions, such as asset freezes, as well as travel bans on individuals or entities involved in the abuse of human rights, democracy or the rule of law. However, currently there are no persons listed under this restrictive measure regime.

The EU Council has commented that the Venezuelan sanctions are being implemented in a gradual and flexible manner, in the hope that it can reverse these sanctions if the Venezuelan government takes credible steps to promote democracy, such as adopting a full electoral calendar and freeing political prisoners. However, if such steps are not taken, the Council has also stated that sanctions may be expanded.

The significant update regarding Iranian sanctions over the previous few months has been the Trump administration's refusal to certify Iran's compliance with the Joint Comprehensive Plan of Action ("JCPOA"), also known as the Iran nuclear deal. The EU Council and several Member States have released statements reaffirming their commitment to the JCPOA (more details can be found in our alert "Iran Nuclear Deal “Decertified” Although Impact Is Uncertain"). The US has since introduced sanctions relating to Iran's ballistic missiles programme.

North Korea
In October 2017, the EU amended the current sanctions imposed on the Democratic People's Republic of Korea ("DPRK") in reaction to the DPRK's continued and accelerated nuclear and ballistics programmes. EU sanctions now include a complete prohibition on investments in any sector within the DPRK (the ban was previously limited to investments in specific sectors) as well as a total ban on the sale of refined petroleum products and crude oil to the DPRK. The amendments also include a reduction of the amount of money an individual can send as a payment or gift from €15,000 to €5,000.

Furthermore, the EU Council froze the assets of and placed travel bans on Kim Jong Sik and Ri Pyong Chol, both senior members of the DPRK Munitions Industry Department as well as Kim Hyok Chan, a representative of Green Pine, a UN listed entity. It also placed asset freezes on six DPRK entities: the Korean People's Army, Ministry of People's Armed Forces, Korea International Exhibition Corporation, North Korea Maritime Administration Bureau, Rungrado Trading Corporation and Wonbang Trading Co. It should also be noted that in November, the EU revised the list of luxury goods subject to import and export bans.

In late December 2017, following the DPRK's ballistic missile tests, the United Nations increased its sanctions on the DPRK. The UN imposed travel bans and asset freezes on an additional 16 individuals and the Ministry of People's Armed Forces (which is already listed by the EU). In January 2018, these sanctions were implemented by the EU. In addition, the UN extended its sanctions to the purchase of agricultural products, food, machinery, electrical equipment, earth, stone, wood and vessels from the DPRK and the sale of industrial machinery, transportation vehicles, iron, steel and other metals to the DPRK. The new sanctions also require all UN member states to repatriate all North Korean nationals earning income with 24 months. The EU has stated that it will implement these additional sanctions in the near future.

Russia and Ukraine
The past two months have seen a number of changes to EU sanctions imposed on Russia. The Governor of Sevastopol, Dmitry Vladimirovich Ovsyannikov, has been added to EU sanctions lists for undermining / threatening Ukraine's territorial integrity, sovereignty and independence. Furthermore, in December the EU extended sanctions on the Russian finance, energy and defence sectors, in response to its role in the current situation in Ukraine, until 31 July 2018.

The EU has also amended its Russian sanctions to allow the provision of technical assistance, financing or financial assistance relating to the trade of hydrazine in concentrations of 70% or more. Such activities are only permitted as long as the hydrazine in question is used in relation to ExoMars 2020, a joint mission between the European Space Agency and Roscosmos State Corporation to deploy a rover on Mars.

Finally, the Russian-owned oil and gas company Rosneft re-launched legal proceedings against EU sanctions affecting it, which were imposed in July 2014. The company will reportedly argue that the EU had not provided significant grounds for imposing sanctions on it as a measure for Russia’s actions in undermining the territorial sovereignty and independence of Ukraine.

Other Jurisdictions
Between October and December 2017, the Council extended the restrictive measures (travel bans and assets freezes) applicable in view of the situation in Burundi, the Democratic Republic of Congo, Moldova and the Republic of Guinea until October and December 2018.

In early November 2017, the EU renewed the listing of Lynn S, a vessel listed under its Libya sanction regime and in early December, the EU removed Iraq Re-insurance Company from its Iraq sanctions list.

The EU has also revised information on the following people listed on its ISIL and Al-Qaida sanctions: Yazid Sufaat, Yunos Umpara Moklis, Radulan Sahiron, Hilarion Del Rosario Santos III and Umar Patek. The EU has also amended the financial sanctions listing of Al-Aqsa Martyr's Brigade.

On 13 November 2017, the Council abolished the restrictive measures against the Colombian group “Fuerzas armadas revolucionarias de Colombia” and decided that the group should be deleted from its list of individuals and entities that are subject to specific restrictive measures with a view to combating terrorism.

On 1 December 2017, the UK Office of Financial Sanctions Implementation renewed financial sanctions on the Popular Front for the Liberation of Palestine.

In November 2017, French and Belgian authorities raided the offices of LafargeHolcim, a Swiss-French cement company and GBL, one of its major shareholders, as part of their investigation into allegations that the company helped finance terrorism in Syria.

In early December 2017, French investigators extended the investigation to three individuals. Two of the individuals, Bruno Pescheux and Frédéric Jolibois, are former directors of the Syrian arm of LafargeHolcim. The third individual accused is Jean-Claude Veillard, a former head of security who is still currently employed by the company. Under French law, in placing these individuals under investigation, the French authorities are indicating that they have serious or consistent evidence that could result in a prosecution.


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.

© K&L Gates LLP | Attorney Advertising

Written by:

K&L Gates LLP

K&L Gates LLP 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 (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

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 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 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 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

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:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (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
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit 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 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:

- 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.