Legal and Practical Considerations of the Trump Administration’s Designation of the IRGC as a Foreign Terrorist Organization

by Akin Gump Strauss Hauer & Feld LLP
Contact

Akin Gump Strauss Hauer & Feld LLP

[co-author: Areej Al Naqbi]

Key Points

  • On April 8, 2019, the U.S. government announced its intention to designate the Islamic Revolutionary Guards Corps (IRGC) as a Foreign Terrorist Organization, effective April 15, 2019. This unprecedented action will result in the first time that the U.S. government has used this designation on a governmental entity.
  • The IRGC is already subject to U.S. sanctions due to a variety of illicit activity over the last decade, but now there will be criminal liability for both U.S. and non-U.S. persons who knowingly provide material support to the IRGC (or attempt or conspire to do so) including agents of the IRGC.
  • Because of the IRGC’s global reach, this action increases the need for heightened due diligence in transactions that may have direct or indirect connections with Iran, including IRGC-owned or-controlled entities anywhere in the world.

On April 8, 2019, the Trump administration announced its intention to designate the IRGC as a Foreign Terrorist Organization (FTO) under Section 219 of the Immigration and Nationality Act.1 The Trump administration’s decision represents the first time that the U.S. government has imposed an FTO designation on a governmental entity, rather than a non-state terrorist organization.

Not only is the IRGC a branch of Iran’s armed forces, but since its inception in 1979, IRGC members and affiliated companies have also gained influence and control across key sectors of the Iranian economy, such as energy, construction, telecommunication, media, mining, electronics, automotive, banking and nuclear, among others.2 The IRGC operates primarily in Iran but has a vast network with reported ties in Afghanistan, Iraq, Lebanon, Syria and Europe.3

Following the decision to designate the IRGC as an FTO, the Trump administration underscored increased responsibility for both U.S. and non-U.S. companies to ensure that their business is not connected in any material way with the IRGC.4 Given the IRGC’s global network of business interests, companies with any direct or indirect connections to Iran would be well served to engage in enhanced diligence to identify any such connections to the IRGC and entities that it owns or controls.

What U.S. Sanctions Targeted the IRGC Before the FTO Designation?

Prior to the Trump administration’s decision to designate the IRGC as an FTO, the U.S. government imposed robust sanctions that specifically targeted transactions with the IRGC. At present, these sanctions operate to prohibit and deter both U.S. and non-U.S. persons from engaging in dealings that have a nexus with the IRGC or entities that are owned or controlled by the IRGC.

U.S. Primary Sanctions

The IRGC was first added to the Specially Designated Nationals and Blocked Persons List (SDN List), on December 19, 2007, for its activities supporting Iran’s effort to secure weapons of mass destruction. Additional sanctions designations followed under separate legal authorities for the IRGC’s human rights abuses and acts of terrorism and, most recently, on October 31, 2017, the U.S. government designated the IRGC as a Specially Designated Global Terrorist (SDGT). This  SDGT designation was imposed pursuant to Section 105 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA), which required the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) to extend terrorism-related sanctions pursuant to Executive Order 13224 to “foreign persons that are officials, agents or affiliates of the IRGC.”5

U.S. persons6 currently face civil and criminal penalties for engaging in virtually any dealing with officials, agents or affiliates of the IRGC listed by OFAC on the SDN List as well as any of their property or interest in property. U.S. persons must also block any IRGC property that comes into their possession or control.7 Pursuant to OFAC’s 50 percent rule, these restrictions extend to any entity that is owned directly or indirectly 50 percent or more by the IRGC, even in circumstances where that entity is not explicitly designated on the SDN List.8 In practice, dealings involving assets associated with the IRGC could present concerns for U.S. persons given that U.S. sanctions broadly prohibit U.S. persons from engaging in business with Iran.

U.S. Secondary Sanctions

The U.S. government also maintains secondary sanctions that target non-U.S. persons that engage in transactions with the IRGC. The U.S. government may impose sanctions on non-U.S. persons for transactions involving the IRGC if they:

  • Act for or on behalf of an official, agent or affiliate of the IRGC.
  • Materially assist, sponsor or provide financial, material or technological support for, or financial or other goods or services to or in support of, officials, agents or affiliates of the IRGC.
  • Knowingly engage in a significant transaction or transactions with the IRGC or any of its blocked officials, agents or affiliates.
  • Otherwise associate with officials, agents or affiliates of the IRGC.

Secondary sanctions are not automatic. Rather, the U.S. government must make a determination that the activity by the non-U.S. person is sufficient to trigger sanctions—i.e., a finding that the conduct was sufficiently “significant” or “material,” terms over which the U.S. government has discretion to interpret broadly. If these factors are met, non-U.S. persons generally face SDN List designation or other sanctions. Non-U.S. persons may also be subject to what are known as “menu-based sanctions”—imposition of five or more measures from a menu of sanctions, which include: prohibitions on property transactions, export license restrictions, Export-Import Bank assistance restrictions, debt and equity restrictions, visa denials for corporate officers and a U.S. government procurement ban,9 or other sanctions within the President’s authority that the President deems appropriate.10

The U.S. government may also impose secondary sanctions on non-U.S. financial institutions that engage in certain prohibited activities that involve the IRGC. These activities include, for example, “knowingly facilitating a significant financial transaction or providing significant financial services for the IRGC or any of its agents or affiliates whose property or interests in property are blocked.”11 The consequences of engaging in these activities include restrictions or prohibitions on opening or maintaining correspondent or payable-through accounts in the United States.

Legal Implications of FTO Designation

Criminal Liability

The FTO designation also provides a basis for criminal liability (a fine or imprisonment of not more than 20 years, or up to life in prison if the death of any person results) over U.S. persons, as well as over non-U.S. persons if they are subject to U.S. jurisdiction, who knowingly provide, or attempt or conspire to provide, “material support or resources” to the IRGC under Section 2339B of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), 18 U.S.C. § 2339B. “Material support or resources” is broadly defined in the statute to include all property, tangible or intangible, and all services, except for medicine and religious materials. Section 2339B of AEDPA applies to U.S. persons, but jurisdiction can also extend to non-U.S. persons in specific instances defined in its extraterritorial jurisdiction clause, including (1) when “conduct required for the offense occurs outside the United States” and the offender is subsequently “brought into or found in the United States,” and (2) when an offense “occurs in or affects interstate or foreign commerce” (emphasis added).12

Civil Liability

The FTO designation provides a basis for civil claims by U.S. nationals under the Antiterrorism Act (ATA) against “any person who aids and abets, by knowingly providing substantial assistance, or who conspires with” an FTO that planned, committed or authorized an act of international terrorism.13 This cause of action also applies extraterritorially, thus resulting in potential additional exposure for non-U.S. persons. The ATA has often been used as a cause of action by individuals injured by acts of terrorism against banks who provide services to designated FTOs.

Legal Implications for the IRGC

The designation of the IRGC as an FTO has legal implications under U.S. law for former and current members of the IRGC. Specifically, the FTO designation calls for the blocking of IRGC assets14 and ban admission into the United States for any alien who is a member of the IRGC.[15] The legal significance of these measures may be limited, however, given that U.S. sanctions authorities targeting the IRGC (as discussed above) already call for the blocking of IRGC property subject to U.S. jurisdiction. Additionally, IRGC members can already be subject to visa bans under specific sanctions authorities and/or face heightened scrutiny and denial of admission to the United States given the organization’s status as an SDGT.

Practical Significance 

Designation of the IRGC as an FTO further increases risks of doing business with or involving Iranian entities, results in additional sanctions exposure for non-U.S. companies that engage in business with IRGC-owned or -controlled entities anywhere in the world, and further negatively impacts risk assessment considerations for international financial institutions with respect to business associated with Iran.

In considering business interests and compliance obligations in this environment, companies should be particularly vigilant in tracking further changes in sanctions laws and U.S. policy affecting their activities and business planning, and be diligent in managing their compliance practices. This includes conducting appropriate diligence in conduct of business activities and transactions, including screening of counterparties, end users and end uses of exports and reexports of goods, technology and services to safeguard compliance with U.S. and other countries’ sanctions and export controls associated with Iran and more broadly. This also means taking care to avoid activities that could be construed as providing support for IRGC officials, agents and affiliates.


1 The White House, “Statement from the President on the Designation of the Islamic Revolutionary Guard Corps as a Foreign Terrorist Organization” (April 8, 2019), https://www.whitehouse.gov/briefings-statements/statement-president-designation-islamic-revolutionary-guard-corps-foreign-terrorist-organization/.

2 Ahmad Majidyar, “IRGC’s Role in Iran’s Economy Growing with its Engineering Arm Set to Execute 40 Mega-projects,” Middle East Institute (May 7, 2018), https://www.mei.edu/publications/irgcs-role-irans-economy-growing-its-engineering-arm-set-execute-40-mega-projects.

3 Michael R. Gordon, Warren P. Strobel, and Nancy A. Youssef, “U.S. to Designate Iranian Guard Corps a Foreign Terror Group,” Wall Street Journal (April 5, 2019), https://www.wsj.com/articles/u-s-to-designate-iranian-guard-corps-a-foreign-terrorist-organization-11554499401?mod=searchresults&page=1&pos=14.

4 Id.

5 CAATSA, § 105(b)-(c) (requiring the President to impose sanctions on the IRGC); Executive Order 13224 (September 24, 2001).

6 The term “U.S. person” means “any United States citizen, permanent resident alien, entity organized under the laws of the United States or any jurisdiction within the United States (including foreign branches), or any person in the United States.” See 31 C.F.R. § 560.314; Executive Order 13224, § 3(c).

7 Executive Order 13224, § 1(c), 2(a).

8 OFAC, “Revised Guidance on Entities Owned by Persons Whose Property and Interest in Property are Blocked” (Aug. 13, 2014), https://www.treasury.gov/resource-center/sanctions/Documents/licensing_guidance.pdf.

9 See Iran Threat Reduction and Syria Human Rights Act of 2012, § 302(a)-(b) (“If the President determines under subsection (a)(1) that a foreign person has knowingly engaged in an activity described in that subsection, the President—(1) shall impose 5 or more of the sanctions described in section 6(a) of the Iran Sanctions Act of 1996.”).

10 See Iran Sanctions Act of 1996, § 6(a).

11 Comprehensive Iran Sanctions, Accountability and Divestment Act of 2010, § 104(c)(2)(E).

12 Specifically, § 2339B allows for extraterritorial jurisdiction when: (a) an offender is a national of the United States or an alien lawfully admitted for permanent residence in the United States; (b) an offender is a stateless person whose habitual residence is in the United States; (c) after the conduct required for the offense occurs an offender is brought into or found in the United States, even if the conduct required for the offense occurs outside the United States; (d) the offense occurs in whole or in part within the United States; (e) the offense occurs in or affects interstate or foreign commerce; or (f) the offender aids or abets any person of whom jurisdiction exists under this provision in knowingly providing material support or resources to the IRGC or conspires with any person over whom jurisdiction exists under this provision to knowingly provide material support or resources to the IRGC.

13 18 U.S.C. § 2333(d)(2).

14 INA § 219(a)(2)(C).

15 INA § 212(a)(3)(B).

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.

© Akin Gump Strauss Hauer & Feld LLP | Attorney Advertising

Written by:

Akin Gump Strauss Hauer & Feld LLP
Contact
more
less

Akin Gump Strauss Hauer & Feld 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 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.