Top Ten International Anti-Corruption Developments for February 2017

by Morrison & Foerster LLP
Contact

Morrison & Foerster LLP

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary resources. This month we ask: What is the latest guidance from the Department of Justice (DOJ) on corporate compliance programs? What did a newly-appointed DOJ official say about the future of FCPA enforcement efforts? What was the outcome of a foreign bribery prosecution in Canada? The answers to these questions and more are here in our February 2017 Top Ten list.

1. DOJ Publishes New Guidance on Evaluating Corporate Compliance Programs.

On February 8, 2017, DOJ’s Fraud Section published an “Evaluation of Corporate Compliance Programs.”  The stated purpose of the guidance is to provide a list of “some important topics and sample questions that the Fraud Section has frequently found relevant in evaluating a corporate compliance program.” The guidance provides a list of 11 topics that DOJ finds relevant in assessing the effectiveness of compliance programs when undertaking an investigation. The list includes such topics as Analysis and Remediation of Underlying Misconduct; Senior and Middle Management; Confidential Reporting and Investigation; and Incentives and Disciplinary Measures. The guidance contains 119 specific questions a prosecutor might ask in the context of an investigation, for example, “[h]as the company reviewed and audited its compliance program in the area relating to the misconduct, including testing of relevant controls, collection and analysis of compliance data, and interviews of employees and third-parties?” The guidance focuses not just on remediation procedures in the context of misconduct, but also relevant policies and procedures and their operation prior to any misconduct having occurred. As such, it can provide useful direction for companies not only undertaking or responding to investigations but also designing or enhancing compliance programs, or simply wishing to benchmark an existing compliance program against the government’s expectations. This is the first guidance publicly issued by the Fraud Section since President Trump took office. The content is consistent with prior guidance, such as the factors listed in the FCPA Resource Guide and Pilot Program, and also reflects the influence of the Fraud Section’s Compliance Counsel, Hui Chen.  

2. Former Executive of Hungary-Based Telecom Company Resolves FCPA Claims with SEC.

On February 8, 2017, Tamas Morvai, a former executive of Magyar Telekom Plc, agreed to pay a $60,000 civil penalty to settle civil FCPA charges brought against him and two other Magyar Telekom executives in 2011. According to the SEC complaint, Morvai, along with Elek Straub and Andras Balogh, violated the FCPA by authorizing €4.875 million in bribes to Macedonian officials in 2005 and 2006 to prevent the introduction of a competitor to the Macedonian telecommunications market and to receive other regulatory benefits. In September 2016, Southern District of New York Judge Richard J. Sullivan rejected the defendants’ claim that SEC had failed to allege a sufficient jurisdictional nexus for the charges, ruling that the defendants’ actions in connection with Magyar Telekom’s EDGAR filings satisfied the FCPA’s jurisdictional requirements. In reaching the settlement, Morvai neither admitted nor denied the allegations. Straub and Balogh are scheduled to begin trial on May 8, 2017. In 2011, Magyar Telekom resolved related allegations with SEC and DOJ by agreeing to pay $31.2 million in disgorgement and prejudgment interest and a $59.6 million criminal penalty.

3. Fugitive in Haiti Teleco Case Appears in Miami Federal Court.

On February 24, 2017, Amadeus Richers, the former general manager of Miami-based Cinergy Telecommunications, appeared in the Southern District of Florida to answer to FCPA and money laundering charges brought against him in a January 2012 superseding indictment. Richers and two other former Cinergy executives, Washington Vasconez Cruz and Cecilia Zurita, are accused of paying bribes to a series of Haitian officials in order to receive favorable treatment from Teleco, the state-owned and state-controlled telecommunications company of Haiti. All three have been considered fugitives since they were first charged in July 2011. The circumstances of Richers’ arrest were not readily apparent on the face of the docket. In March 2012, a Miami federal jury convicted former Teleco official Jean Rene Duperval of laundering bribes that he received from Cinergy and another Miami-based telecommunications company in exchange for various benefits, including reduced telecommunication rates. The Supreme Court denied Duperval’s petition for certiorari in January 2016. Eight other individuals were also convicted in connection with the Haiti Teleco investigation.

4. Austrian Appeals Court Approves Extradition of Ukrainian Billionaire to United States in Connection with India FCPA Allegations.

On February 21, 2017, an Austrian appeals court approved the extradition of Dmitry Firtash to the United States to face accusations that he conspired to pay at least $18.5 million in bribes to government officials in India to allow the mining of titanium minerals, in violation of the FCPA and other statutes. The decision reverses an April 2015 lower court ruling that extradition was improper because the charging decision was politically motivated. Firtash was indicted in 2013 in the Northern District of Illinois and was arrested in 2014 in Vienna, where he has resided ever since. Shortly after the appellate court decision, Firtash was taken into custody on a European arrest warrant related to a separate request by Spain, apparently on money laundering charges. Firtash’s arrest on the second warrant raises the possibility that he may be extradited to Spain rather than to the United States.

5. Texas-Based Oil Exploration Company Announces DOJ Declination in Angolan FCPA Investigation.

On February 9, 2017, Cobalt International Energy, Inc. issued a press release announcing that it received a letter from DOJ advising that the Department had closed its FCPA investigation into the company’s Angola operations. The investigation, along with a related SEC investigation, began in 2011 following allegations of a connection between senior Angolan officials and two Angola-based companies assigned to Cobalt’s exploration group in Angola. Despite having received a Wells Notice in August 2014, Cobalt announced in January 2015 that it had received a termination letter from SEC. 

6. Jury Awards Life Sciences Company’s Former General Counsel nearly $11 Million in Whistleblower Retaliation Suit.

On February 3, 2017, a jury in the Northern District of California found that Bio-Rad Laboratories, Inc. violated the Sarbanes-Oxley Act’s whistleblower protections when it fired its former general counsel, Sanford Wadler, for reporting possible FCPA violations. According to Wadler’s June 2015 retaliation complaint, Wadler reported to the company’s audit committee in 2013 that he suspected the company had violated the FCPA in China. He was fired later that year. Wadler argued that he was fired for blowing the whistle, while the company argued he would have been fired anyway due to frequent outbursts, a lack of understanding of the company’s operations in China, and poor FCPA compliance in general. The jury agreed with Wadler, finding that his report to the board was protected whistleblower activity and was a substantial motivating reason for his termination. The jury awarded Wadler $2.9 million in back pay and stock compensation, and another $5 million in punitive damages. Because back pay damages are doubled, the total award amounted to $10.8 million. Prior to trial, United States Magistrate Judge Joseph Spero rejected the company’s October 2016 motion to exclude evidence and testimony by Wadler on the grounds that his claims are “inextricably intertwined” with its privileged and confidential information.

7. Foreign Bribery Prosecution Ends in Acquittals in Canada.

On February 10, 2017, two former SNC-Lavalin executives and a Bangladeshi-Canadian businessman were acquitted in Ontario Superior Court of charges that they had violated the Corruption of Foreign Public Officials Act by scheming to bribe Bangladeshi officials in connection with a multibillion-dollar contract to build the Padma Multipurpose Bridge. In January 2017, the Superior Court excluded evidence derived from a wiretap that the Royal Canadian Mountain Police had obtained based on information provided by the World Bank, which the court found amounted to uncorroborated speculation, gossip, and rumor. The prosecution elected to present no other evidence against the defendants, resulting in their acquittals. In 2014, the same Superior Court justice had ordered the World Bank to produce its investigative file in connection with the defendants’ motion challenging the wiretap. That order was reversed by the Canadian Supreme Court in April 2016 in a strongly worded opinion extolling the importance of cooperation between the World Bank and national law enforcement authorities. Canadian prosecutors had previously dropped charges against two other defendants. Although clearly a setback to Canada’s foreign bribery enforcement efforts, Canadian prosecutors were successful in their first ever COFPA prosecution, securing the conviction of Nazir Karigar in 2013 for plotting to bribe Indian officials to win a contract to provide security technology to a state-owned airline.

8. “Panama Papers” Lawyers Arrested in Panama.

On February 9, 2017, Panamian authorities reportedly raided the offices of Mossack-Fonseca, the law firm at the center of the Panama Papers controversy, and on February 11, 2017, reportedly arrested the name partners of the firm. Jurgen Mossack and Ramon Fonseca were taken into custody and formally detained in Panama City on money laundering charges related to “Operation Car Wash,” a sweeping investigation into alleged bribery involving Brazil’s state-owned oil company, Petróleo Brasileiro S.A. (“Petrobras”). Panama’s Attorney General reportedly highlighted that the one-year investigation that led to the arrests has been aided by prosecutors in Brazil, Colombia, Ecuador, Peru, Switzerland, and the United States, demonstrating the continued international reach of what began as a domestic corruption investigation in Brazil.

9. New Deputy Assistant Attorney General Discusses the “Continuity and Evolution” of FCPA Enforcement.

On February 16, 2017, Trevor McFadden, the newly appointed deputy assistant attorney general (DAAG) of DOJ’s Criminal Division, delivered keynote remarks at a conference in Washington, DC, in which he “highlight[ed] the continuity and evolution” of FCPA enforcement. After tracing the history of FCPA enforcement through the 1980s and 1990s, McFadden, likely seeking to underscore the bipartisan nature of FCPA enforcement, noted that the “most robust period of FCPA enforcement” began under President George W. Bush and continued under President Barack Obama. McFadden also stressed the institutionalized nature of FCPA enforcement, pointing to DOJ’s FCPA Unit (which he noted had grown to 31 attorneys since its formation in 2005), the FBI’s dedicated FCPA squads, and increased international cooperation. McFadden made three points regarding the future of FCPA enforcement: (1) Attorney General Sessions has said that DOJ will continue to enforce the FCPA and corruption laws generally; (2) Attorney General Sessions has said that DOJ will continue to hold individuals accountable, meaning that DOJ will continue to prosecute individuals for FCPA violations; and (3) three mitigating factors—self-disclosure, cooperation, and remediation—will continue to guide DOJ’s prosecution decisions and its efforts to further compliance goals. Although President Trump has yet to nominate anyone to lead the Criminal Division, McFadden’s responsibilities as DAAG include oversight of the Criminal Division’s Fraud Section, which has sole jurisdiction over criminal FCPA enforcement. For those wondering what FCPA enforcement will look like under the Trump administration, McFadden’s remarks provide at least one data point suggesting that FCPA enforcement may change at the margins but is unlikely to go away.

10. SEC Resource Extraction Disclosure Rules Repealed.

On February 14, 2017, President Trump signed into law a joint resolution of Congress that vacated SEC’s rules requiring resource extraction disclosures. The rules, mandated by the 2010 Dodd-Frank Wall Street Reform and Consumer Protection Act and announced by SEC in June 2016, required resource extraction issuers to disclose payments made to governments for the commercial development of oil, natural gas, or minerals. (An earlier version of the rules was vacated in 2013 by the U.S. District Court for the District of Columbia.) The rules, similar to Canada’s Extractive Sector Transparency Measures Act (see our client alert) and several European initiatives, were designed to increase transparency and decrease corruption in the extractive industry. Critics argued that the rules went beyond SEC’s core mission and put American companies at a disadvantage. During a February 24, 2017 speech, SEC Acting Chairman Michael S. Piwowar said that he had asked the SEC staff “to take a fresh look at the rule mandate to determine how we can comply with our statutory obligations in a manner that better aligns with our core mission.”

[View source.]

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

© Morrison & Foerster LLP | Attorney Advertising

Written by:

Morrison & Foerster LLP
Contact
more
less

Morrison & Foerster 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.