UK Criminal Finances Act 2017: A Dechert "Dirty Money" Trilogy

by Dechert LLP

Dechert LLP

Part One: "A Fistful of Tax Dollars" - A New Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion

The Criminal Finances Act 2017 represents a further significant development in the approach to the investigation and prosecution of financial crime in the UK.1 The new offence of failure to prevent the facilitation of tax evasion and changes to the regime for suspicious activity reports will require entities which carry on business in the UK to take a yet more active role in the detection and prevention of potential financial crime, and to further examine and update their compliance policies and procedures. New unexplained wealth orders ("UWOs") may also place onerous requirements on individuals and companies to explain the source of their assets in the UK and beyond.

This OnPoint – the first of a Dechert “trilogy” on the Criminal Finances Act 2017 - focuses on the new corporate offence of failure to prevent the facilitation of tax evasion. Two further OnPoints will follow: (a) "For a Few Days More" which will explain the reform of the suspicious activity reporting regime and (b) "The Good the Bad and the Wealthy" which will examine new unexplained wealth orders.


In one of its final acts before it dissolved ahead of the upcoming general election, the UK Parliament passed the Criminal Finances Act 2017 (the “Act”), which received Royal Assent on 27 April 2017. When the Act comes into force, it will develop the financial crime enforcement landscape in the UK. in a manner which will affect individuals and corporates alike. Most notably, the Act:

  1. Introduces a new offence of failure to prevent the facilitation of tax evasion; and
  2. Grants UK authorities additional powers to combat financial crime, including via:

a) Reform of the suspicious activity reporting regime; and
b) New unexplained wealth orders.

Key Takeaways

  • New corporate offence of failure to prevent the facilitation of tax evasion. This new offence is designed to revolutionise corporate attitudes to tax-sensitive activities, and places the onus on corporates to stop persons who act for it, or on its behalf, from facilitating tax evasion wherever in the world it occurs. Corporates should prepare to undertake a risk assessment and implement prevention procedures (including enhancements to existing compliance policies and procedures) to mitigate business risk arising from the new offence.
  • Reform of the suspicious activity reporting regime. In order to minimise the risk of serious disruption to their day-to-day business, entities in the UK regulated sector must be prepared to take a more pro-active approach to analysing whether a suspicious activity report is genuinely required, rather than routinely filing suspicious activity reports.
  • Unexplained wealth orders. UWOs place onerous requirements on individuals or companies to explain the source of their assets in the UK and beyond. It is not presently entirely clear how UWOs will be used in practice, and we foresee that they will likely be subject to multiple challenges in UK courts.

Corporate Offence of Failure to Prevent the Facilitation of Tax Evasion


Historically, it has proved notoriously difficult to prosecute corporates in the UK - particularly large, complex organisations - due to the need to demonstrate that relevant acts were carried out by senior individuals who represented the “directing mind and will” of the company (the so-called “identification principle”).

In recent years, the UK has sought to reform this area of law, including by adopting a new type of offence, criminalising a corporate for “failure to prevent” a criminal offence being committed. This type of offence imposes strict liability on an entity unless it can demonstrate it has certain preventative measures in place. The first example of this type of offence in relation to financial crime2 is under section 7 of the Bribery Act 2010, which imposes strict liability on a company for failure to prevent bribery by a person associated with it, unless it can show that it had adequate procedures in place to prevent bribery. A Government consultation is currently ongoing in relation to the reform of corporate criminal liability, and a more general extension of the “failure to prevent model” is under consideration.3

The Offences

In the meantime, the Act creates two new “failure to prevent” offences under UK law:

  • Failure to prevent facilitation of UK tax evasion; and
  • Failure to prevent facilitation of foreign tax evasion.

The basic requirements for both offences are the same. A body corporate or partnership (which includes a “firm or entity of a similar character formed under the law of a foreign country”) is guilty of an offence if an “associated person” of that body (i.e. an employee, agent or any other person acting for and on behalf of that body), who is acting in such a capacity, commits a (UK or foreign) tax evasion facilitation.4

The consequences of a conviction are potentially severe and include an unlimited fine and the possibility of prohibition from bidding for public contracts.

The offences also have extra-territorial effect. None of the conduct of either the relevant body or any other person whose conduct constitutes part of either the original tax evasion or connected tax evasion facilitation needs to have occurred in the UK.

In essence, the offences consist of three stages:

1. Criminal tax evasion by a taxpayer (either an individual or a legal entity) under existing law. For these purposes:

  • A “UK tax evasion offence” includes the broad common law offence of cheating the public revenue and any other offence under UK law which concerns “being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of a tax”.  Dishonesty is a necessary element of the UK tax evasion offence.
  • A “foreign tax evasion offence” catches conduct which: (a) amounts to an offence in a foreign country; (b) relates to a breach of a duty relating to a tax under the laws of that country; and (c) would constitute an offence of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of a tax if it took place in the UK (the “dual criminality” requirement).

2. Criminal facilitation of the tax evasion by an “associated person” of the relevant body who is acting in that capacity. For these purposes:

  • A “UK tax evasion facilitation offence” consists of: (a) being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax by another person; (b) aiding, abetting, counselling or procuring the commission of a UK tax evasion offence; or (c) being involved “art and part5 in the commission of an offence of being knowingly concerned in, or taking steps with a view to, the fraudulent evasion of tax.
  • A “foreign tax evasion facilitation offence” means conduct which: (a) amounts to an offence under the law of a foreign country; (b) relates to the commission by another person of a foreign tax evasion offence under that law; and (c) would, if the foreign tax evasion offence were a UK tax evasion offence, amount to a UK tax evasion facilitation offence (the dual criminality requirement).

This stage requires that the associated person must deliberately and dishonestly take action to facilitate the taxpayer-level evasion.  If the associated person is only proved to have accidentally, ignorantly or even negligently facilitated the tax evasion offence then the new offence is not committed by the relevant body.6

3. The relevant body failed to prevent its representative from committing the criminal facilitation act.

Where stages one and two are met, the relevant body will be guilty of the offence unless it can demonstrate that, when the tax evasion facilitation offence was committed:

  • It had in place such prevention procedures as were reasonable in all the circumstances of the case; or
  • It was not reasonable in the circumstances for there to be any prevention procedures in place.

Notably, the requirement for prevention procedures appears somewhat less burdensome than the corresponding “adequate procedures” requirement under the Bribery Act 2010. The relevant body must only show that it had “reasonable” (rather than “adequate”)7 prevention procedures in all the circumstances, and the Act even envisages that, in some circumstances, it may not be reasonable to expect the relevant body to have any prevention procedures in place at all. This argument is only likely to be deployed after-the-event where it was not envisaged that there was a risk of tax evasion being facilitated by an associated person. Where a company has identified a risk and sought advice to mitigate its, it is difficult to envisage circumstances in which it would be appropriate to advise that no procedure at all should be deployed.

Section 47 of the Act requires that the Chancellor of the Exchequer prepare and publish guidance about procedures that relevant bodies can put in place to prevent persons acting in the capacity of an associated person from committing UK tax evasion facilitation offences or foreign tax evasion facilitation offences. This has not yet been issued but the Draft Government Guidance published in October 2016 (the “Draft Guidance”) sets out six “guiding principles” for relevant bodies designing their own “bespoke prevention procedures”, which mirror the six principles in the Bribery Act 2010 Guidance issued by the Ministry of Justice:

  1. Risk assessment;
  2. Proportionality of risk-based prevention procedures;
  3. Top-level commitment
  4. Due diligence;
  5. Communication (including training); and
  6. Monitoring and review.

In order to encourage corporates to disclose relevant wrongdoing, the Draft Guidance states that “timely self-reporting will be viewed as an indicator that a relevant body has reasonable procedures in place”. The Act and Draft Guidance do not specify to whom a corporate should self-report wrongdoing, nor the consequences for failing to do so, though the Draft Guidance states that the UK tax offence will be investigated by HMRC, with prosecutions brought by the Crown Prosecution Service (“CPS”), whilst the foreign tax offence will be investigated by the Serious Fraud Office (“SFO”) or National Crime Agency, with prosecutions brought by either the SFO or CPS. It will also be possible for relevant bodies to enter into a Deferred Prosecution Agreement with the relevant prosecutor in relation to the offence.8


It is unlikely that there will be very many prosecutions for these new offences, which will each require two underlying offences to be proved to the criminal standard (see stages one and two above). The UK also has a poor track record for convictions for tax evasion, not least due to the difficulty of distinguishing (illegal) tax evasion from (legal) tax avoidance. Prosecuting authorities may also struggle to demonstrate that the dual criminality requirements for the foreign failure to prevent offence are satisfied. Expert evidence will be required to establish the application of foreign law and is likely to provide fertile ground for argument.

Nonetheless, the potential impact of the new offences on entities which carry on at least part of their business in the UK is far-reaching and burdensome. A conviction on indictment can result in an unlimited fine and may lead to debarment from bidding on public contracts. The extra-territorial effect of the offences further means that relevant entities, which may be headquartered abroad, will be criminally liable if they do not have reasonable procedures in place to prevent an associated person abroad committing an offence of tax evasion abroad.

With that in mind, prudent corporates should undertake a risk assessment in relation to their business operations and should implement such prevention procedures (including any related enhancements to compliance policies and procedures) as are necessary to mitigate the risks to their business as soon as possible.


1) We refer in this OnPoint to both UK-wide laws and courts, and the laws and courts of England and Wales as “UK law” or “UK courts” for simplicity.  The Act contains a number of Scotland-specific provisions, which this OnPoint does not consider.

2) It has been possible for companies and organisations to be found guilty of corporate manslaughter since the Corporate Homicide Act 2007 came into force on 6 April 2008, and for wider healthy and safety offences since the Health and Safety at Work etc. Act 1974 came into force on 1 October 1974.

3) Consultation: Corporate liability for economic crime

4) The offence of failure to prevent a foreign tax evasion facilitation will apply to a relevant body that: (a) is incorporated or formed in the UK; (b) carries on business or part of a business in the UK; or (c) carries on conduct constituting part of the foreign tax evasion facilitation offence in the UK.

5) This being the Scottish equivalent of aiding and abetting under English law.

6) HM Revenue & Customs, “Tackling tax evasion: Government guidance for the corporate offence of failure to prevent the criminal facilitation of tax evasion” (Draft Government Guidance; Updated October 2016).

7) The language used to describe both (i) “reasonable prevention procedures” in the draft government guidance for the corporate offence of failure to prevent the facilitation of tax evasion and (ii) “adequate procedures” in the Bribery Act 2010 Guidance is very similar (both state that such procedures will be “proportionate” to the risk the relevant body faces).  UK courts have not yet considered the term “adequate procedures” under the Bribery Act 2010.  It could be argued that adequate procedures may be judged by its capacity to prevent the circumstances which occurred, whereas reasonable procedures may be judged more from the standpoint of the business.  UK prosecutors could conceivably argue against an “adequate procedures” defence on the basis that that any procedures which failed, in fact, to prevent an instance of bribery to occur were demonstrably inadequate.  By contrast, the term “reasonable” is much more subjective, and would appear to offer greater discretion to a court or prosecutor when considering whether a relevant body’s prevention procedures were in fact proportionate to the risks faced, and would thus appear to offer a greater opportunity to relevant organisations to run this defence.  A court could consider that the term “reasonable” is equivalent to the phrase “reasonably practicable”, a phrase which is commonly used in health and safety law (for example, section 2 of the Health and Safety at Work etc. Act 1974 uses the term “so far as is reasonably practicable” in relation to the general duties of employers to their employees).

8) Our recent OnPoint, “Every Little Helps with a DPA”, examines recent developments in relation to Deferred Prosecution Agreements.


Written by:

Dechert LLP

Dechert 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.