Key Considerations for U.K. Investment in the Legal Cannabis Industry Abroad

Faegre Drinker Biddle & Reath LLP

Faegre Baker Daniels

U.K. investors in cannabis-related entities, where the activity is legal in its jurisdiction but not legal in the U.K., risk committing money laundering offences under the Proceeds of Crime Act 2002 (POCA). However:

  • Various defences may be available under POCA (as set out below).
  • The legality of the investment can be safeguarded by making an authorised disclosure to the National Crime Agency (NCA) and receiving consent to proceed with the specific proposed activity (be it selling existing investments, holding them and receiving dividends, or making new investments).
  • Correct structuring of an investment is key to ensuring that the investment can be made lawfully.

That said, the legal position is not clear cut. There is very little guidance for U.K. businesses with regards to cannabis-related activity and significant discrepancy in opinion within the U.K. investment community as to the boundaries of legal risk and compliance. The position of the NCA and other regulators is not clear, whilst Lloyd’s of London guidance varies by jurisdiction, as outlined below. On 18 June 2019, the U.K. Law Commission published a report, “Anti-money laundering: the SARs regime”, highlighting the need for guidance on transactions involving the legal cannabis industry in Canada and elsewhere.

In the meantime, U.K. investors will need to remain alive to the risk that returns from the Canadian or U.S. cannabis industries may be considered proceeds of crime and conduct appropriate due diligence (and make disclosures if necessary) in accordance with their risk appetite.

Legal Status of Cannabis in the U.K., U.S. and Canada


In the U.K., cannabis is illegal for recreational use and is classified as a Class B drug under the Misuse of Drugs Act 1971. Medical use of cannabis when prescribed by a registered specialist doctor was legalised in November 2018. The possession of cannabis carries a sentence of up to 5 years in prison, an unlimited fine or both, and the supply and production of cannabis carries a sentence of up to 14 years in prison, an unlimited fine or both.


In the U.S., the use and possession of cannabis over 0.3% THC (legal term “marijuana”) is classified as a Schedule 1 drug and is illegal under federal law for any purpose (with the exception of FDA-approved research programs) by way of the Controlled Substances Act 1970.

However, individual states have enacted legislation permitting exemptions for various uses, mainly for medical and industrial use but also recreational use. This has not changed federal law; the Department of Justice has instructed prosecutors to refrain from prosecuting by way of the Cole Memorandum, issued in August 2013 to all U.S. Attorneys, governing federal prosecution of offenses related to marijuana. The memo stated that given its limited resources, the Department of Justice would not enforce the federal marijuana prohibition in states that “legalized marijuana in some form and ... implemented strong and effective regulatory and enforcement systems to control the cultivation, distribution, sale, and possession of marijuana,” except where a lack of federal enforcement would undermine federal priorities (such as preventing violence in marijuana cultivation and distribution, preventing cannabis impaired driving, and preventing marijuana revenues from going to gangs and cartels).


Since 17 October 2018, it has been legal to produce, distribute, sell and possess cannabis in Canada (for all purposes including medical and recreational), subject to complying with the provisions of the Canadian Cannabis Act.

Relevant U.K. Statute


POCA contains various money laundering offences relating to the direct handling of the proceeds of crime. A person commits an offence if he or she:

  • Conceals, disguises, converts, transfers the proceeds of crime or removes criminal property from the jurisdiction of England and Wales (s327) (the basic money laundering offence).
  • Enters into or becomes concerned in an arrangement which he or she knows or suspects facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (s328) (the aiding and abetting offence).
  • Acquires, uses or possesses criminal property (s329) (the handling stolen goods offence).

“Criminal property” is defined in s340(3) and s413(1) of POCA as property which constitutes a person’s benefit from criminal conduct or which represents such a benefit (in whole or in part and whether directly or indirectly).

“Criminal conduct”, under s340(2) of POCA, is conduct which constitutes an offence in any part of the U.K. or would constitute an offence in any part of the U.K. if it occurred there.

The above definitions bring cannabis, including cannabis grown and distributed legally abroad, within the scope of POCA, thereby creating an issue for U.K. investors.

The SOCPA or “Spanish Bullfighter” Exception

The Serious Organised Crime and Police Act 2005 (SOCPA) provides an exception to the above offences (the “Spanish bullfighter” exception) in relation to conduct that is legal in other jurisdictions. A person does not commit an offence if:

  • They know or believe, on reasonable grounds, that the relevant criminal conduct occurred outside the U.K.,
  • The relevant criminal conduct was not, at the time it occurred, unlawful under the criminal law then applying in that territory, and
  • The relevant criminal conduct is not of a description prescribed by an order made by the Secretary of State.

For example, a bullfighter from certain parts of Spain (where the practice is legal) could come to the U.K. (where it is not) and spend his earnings without fear of committing an offence under POCA.

However, the above exception regarding orders made by the Secretary of State brings cannabis-related businesses back within the scope of POCA; the Proceeds of Crime Act 2002 (Money Laundering: Exceptions to Overseas Conduct Defence) Order 2006 provides that conduct which would constitute an offence punishable by imprisonment for a maximum term in excess of 12 months in any part of the U.K. does not form part of the Spanish bullfighter exception. The cultivation, possession, distribution (etc.) of cannabis all carry sentences of greater than 12 months.

Defences and Safeguards

Adequate Consideration

Section 329(2)(c) POCA contains a specific defence to the offence of acquiring, using or possessing criminal property, which is that a person does not commit an offence if they acquired their property for “adequate consideration”. Consideration would be “inadequate” for these purposes if it was significantly less than the value of the relevant property. Therefore, shares purchased in a public company for market value would not constitute criminal property. The right to the benefits derived from those shares, such as dividends and capital growth, should also be considered to have been purchased for adequate consideration, albeit this position has not been tested and confirmed in the U.K. courts.

U.K. shareholders should therefore be entitled to rely on the adequate consideration defence to permit them to (i) purchase shares in companies exposed to the cannabis industry, (ii) receive dividends paid on those shares, and (iii) sell those shares for a profit if the share price has risen since they were acquired, in each case without such conduct constituting an offence under s329. It must be noted, however, that in relation to points (i) and (iii), offences under s328 and s327 POCA (respectively) may still be committed. It is therefore imperative to ask when the relevant activity took place and consider any available defences accordingly.

Authorised Disclosure

POCA also specifies a method to ensure that the various money laundering offences would not be committed; under s327(2), s328(2) and s329(2), a person does not commit an offence if they make an “authorised disclosure” and obtain the appropriate consent. This “authorised disclosure” takes the form of a suspicious activity report (SAR) that is typically submitted to the NCA.

The NCA may give “active” consent (i.e. respond saying that consent is granted), or, if the NCA does not respond to an SAR within seven working days from the first working day after submission, then they are deemed to have given consent and the person may proceed (s335(5) POCA).

Note, however, that an SAR cannot be used to obtain “blanket” permission. To adhere to the SAR regime, an investor would technically have to submit an SAR each time they decide to take any action in respect of their “criminal property”, e.g. purchasing shares, receiving dividends or selling shares. Investors might therefore burden themselves with various reporting obligations as well as the NCA with excessive numbers of reports to process.

U.K. Public Policy

This type of activity is not what POCA was designed to criminalise, and it is considered unlikely that the U.K. authorities would actively seek to prosecute for it. Moreover, the SOCPA exception indicates that U.K. legislation has been narrowed to avoid unintended consequences.

Timing of the Investment

According to the English cases of R v Loizou [2004], R v Geary [2010] and GH [2015], property must be “criminal property” at the time the alleged criminal activity was undertaken. Therefore, individuals who invest in companies that do not have a connection to the cannabis industry but subsequently change their business to include cannabis-related activity will not commit an offence until they begin to receive proceeds generated by that activity.

In R v Geary, the Court of Appeal held that “property becomes criminal property only when a person obtains an interest in it as a result of, or in connection with, criminal conduct, that is, conduct which constitutes a criminal offence” and “criminal property must already have come into existence in order for an offence to be committed under section 328 or 329”. This means that a U.K. company or individual investing lawful money into a new cannabis venture would not be committing an offence under s328.


Whilst English law presumes that English criminal statutes do not extend to acts wholly undertaken outside the U.K., the Court of Appeal decision R v Rogers [2014] significantly (and somewhat surprisingly) extended the scope of POCA to conduct that occurs entirely outside the U.K., subject to the restriction that a significant part of the underlying criminality must have taken place in the U.K. and it had harmful consequences in the U.K..

Rogers, a U.K. citizen resident in Spain, permitted money from a fraudulent scheme in the U.K. to be paid into his Spanish bank account and allowed the fraudsters to withdraw money from that account. He was convicted of converting criminal property. The Court of Appeal upheld the conviction because a significant part of the underlying criminality took place in the U.K. and it had harmful consequences in the U.K.

The effect of this is that, provided all actions are undertaken outside the U.K., the sale of shares or assets and collection of dividends outside the U.K. would not constitute a crime in the U.K.

However, were investors to move their returns into the U.K. they could be guilty of converting or transferring criminal property under s327 POCA, because the returns arise from an activity that, had it taken place in the U.K., would have been a criminal offence.

Therefore, the investment itself, the mere holding of the shares and the receipt of proceeds outside the U.K. would not constitute offences under English Law.

Note however, that the position regarding a U.S. cannabis-related entity (as opposed to Canadian) is more complex due to the status of federal law on marijuana, which provides for nonenforcement in respect of certain activities which remain illegal under federal law.

Lloyd’s of London Commentary

Lloyd’s of London Market Bulletins are the formal means of advising the Lloyd's market of business-critical issues.


In its Market Bulletin of 30 August 2018, Lloyd’s stated that its underwriters are well-positioned to write Canadian cannabis business subject to compliance with local Canadian requirements:

“Having taken advice from specialist Leading and Junior Counsel, Lloyd’s is satisfied that:

  • Providing insurance for Canadian cannabis risks would not amount, in the circumstances under consideration, to entering into, or becoming concerned in, an arrangement which facilitates the acquisition, retention, use or control of criminal property by another person thereby breaching section 328 POCA.
  • That neither POCA – nor any of its statutory predecessors – was designed to bring wholly lawful conduct such as the provision of insurance of business activity carefully legalised in another country, into its scope.
  • This view is consistent with the Explanatory Notes to POCA, including for example paragraph 6 which states that the statute’s purpose was to criminalise money laundering in its broadest form which “is the process by which the proceeds of crime are converted into assets which appear to have a legitimate origin so that they can be retained permanently or recycled into further criminal enterprises” – this is far removed from Lloyd’s underwriters openly and properly providing businesses in Canada with insurance against a conventionally covered ascertainable external event”.


In its Market Bulletin of 25 May 2016, Lloyd’s stated that:

“Based upon a thorough review of all positions, unless and until the sale of either medicinal or recreational marijuana is formally recognized by the Federal government as legal (as opposed to subject to non-enforcement directives), underwriters should not insure such operations in any form (including crop, property, or liability cover for those who grow, distribute or sell any form of marijuana or cover for the provision of banking or related services to these operations) in the United States.

Coverage may be provided to non-marijuana-related businesses with incidental marijuana exposures (e.g. a pharmacy or physician where a small amount of their business may include marijuana products or prescriptions) if losses arising from such exposures are expressly excluded from cover”.

Other Commercial Considerations (U.S.)

In the U.S., because of the status of federal law, state-legal marijuana businesses often have difficulty accessing the banking and accounting industries due to the extensive and onerous due diligence and filing obligations imposed on financial institutions providing them services.

The U.S. Financial Crimes Enforcement Network Guidance on Bank Secrecy Act Expectations Regarding Marijuana-Related Businesses requires financial institutions to conduct extensive and ongoing due diligence on cannabis-related entities they may provide services to, particularly in relation to breaching the federal priorities outlined in the Cole Memorandum.

In addition, financial institutions that subsequently decide to provide services to any marijuana-related business are required to file an SAR in relation to that business, including where it is duly licensed under state law. The SAR will be titled (i) “Marijuana Limited” where, based on the due diligence conducted, no suspicious activity has been identified, (ii) “Marijuana Priority” where, based on the due diligence conducted, the marijuana-related business implicates one of the Cole Memorandum priorities or violates state law, or (iii) “Marijuana Termination” where a financial institution deems it necessary to terminate its relationship with a marijuana-related business in order to maintain an effective anti-money laundering compliance program.

The law is stated as of July 2019 and is continually evolving.

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.

© Faegre Drinker Biddle & Reath LLP | Attorney Advertising

Written by:

Faegre Drinker Biddle & Reath LLP

Faegre Drinker Biddle & Reath 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.