United States: Caught Between A Great Wall And A Hard Place: Issues For U.S. Public Companies In Responding To Regulatory Requests For Chinese Data

Introduction

In January 2014, a Securities and Exchange Commission administrative law judge (''ALJ'') sanctioned five Chinese affiliates of major U.S. public accounting firms (the ''Firms'') for their failure to produce work papers related to their auditing of ten U.S. issuers with operations in China.1 At the time of the document requests, the issuers were under investigation by the SEC for alleged fraud. The ALJ ordered the sanctions despite the fact that Chinese regulators had expressly forbidden the Firms from producing their work papers, and notwithstanding the Firms' documented concerns that direct production could subject them to criminal prosecution under China's State Secrets Law.2 The ALJ had ''little sympathy'' for the Firms, pointing to the lucrative audit work they had obtained and stating that if they were between a rock and a hard place, ''it is because they wanted to be there.''3

Whether in the context of securities fraud, anticorruption, antitrust, or consumer protection, U.S. enforcement agencies now routinely investigate the Chinese operations of U.S. issuers. Public companies operating in China are almost certain to face SEC requests seeking the production of materials located in China. Moreover, even a company's responsible efforts to conduct an internal investigation raises significant questions of how (or whether) to export Chinese data. Increasingly, professional services firms engaged to process data for internal investigations demand representations from clients that their China-based data does not contain sensitive information that could trigger potential violations of the State Secrets Law.

Given this dilemma—chance criminal prosecution in China or face sanctions in the U.S.—companies encountering these conflicting legal obligations should adopt practical solutions to mitigate the risks. Focusing on the specific concerns facing U.S. issuers with operations in China, this article: (1) describes how the Firms in Dahua attempted to navigate between the SEC and the Chinese government; (2) outlines an approach for mitigating some of the risks of responding to U.S. information requests for Chinese data; and (3) suggests other areas where these issues may impact U.S. public companies, including: independent auditor engagements, enforcement resolution negotiations with U.S. authorities, and the ongoing involvement of the Dahua Firms in the preparation of their audited financials.

The Approach Taken by the Chinese Accounting Firms

In the investigations of the ten Chinese issuers, the SEC served subpoenas directly on the issuers and the Chinese auditors' U.S. affiliates, and sent voluntary production requests to the Firms. When these methods failed to secure production of the work papers, the SEC served Sarbanes-Oxley Act (''SOX'') § 106 demands on each of the Firms.4

The Firms used a two-pronged approach to navigate between the China Securities Regulatory Commission (''CSRC'')5 and the SEC. They attempted to convince the SEC that their fears of criminal prosecution in China were genuine and that they had done everything possible to obtain permission from the CSRC, while simultaneously urging the CSRC to either permit direct production of their work papers or implement an approved process for delivery of the materials to the SEC.

Each of the Firms indicated to the SEC that they were willing but unable to comply with the SOX § 106 demands. They explained to the SEC staff that production could subject them to, among other sanctions, criminal prosecution under the State Secrets Law. The Firms supported these claims by producing evidence of their repeated efforts to obtain permission from the CSRC, the Ministry of Finance (''MOF''), the State Secrets Bureau and the Archives Bureau, by demonstrating their receipt of multiple warnings from the CSRC and MOF, and by producing Chinese legal opinions indicating that the direct production of work papers to the SEC could expose them to criminal and civil liability. The CSRC repeatedly informed the Firms—including during an unprecedented group meeting that included senior officials from the MOF—that complying with the SEC's requests would result in significant liability, license revocation, and ''personal'' consequences.6 The CSRC declined to provide the Firms with guidance on precisely what information within their work papers could constitute ''state secrets'' for purposes of Chinese law.7

On their side, the SEC staff attorneys were frustrated by their inability to obtain copies of the work papers through their CSRC counterparts. Despite the existence of at least four cooperation agreements between the SEC and CSRC, the SEC's Office of International Affairs (''OIA'') advised the investigating attorneys that previous similar requests to the CSRC had been fruitless. Although each of the Firms asked the SEC to utilize an agency-to-agency production process, the SEC staff insisted that they produced their work papers directly.8

Although the Firms notified the SEC that the CSRC had begun developing pre-production screening guidelines that would facilitate the production of their work papers to the CSRC for delivery to the SEC, the SEC nevertheless instituted administrative proceedings alleging that the Firms had willfully refused to produce their work papers in violation of SOX and the Securities Exchange Act of 1934. In January 2014, the ALJ found that the Firms had not acted in good faith in responding to the SEC's information requests and had ''willfully refused'' to produce their work papers in violation of SOX § 106. The ALJ ordered six-month bars from practice and censures for four of the Firms, and censured, but did not bar, the BDO affiliate.9

A Practical Approach to Information Requests Related to China

Although there is no easy solution for the dilemma of conflicting cross-border regulatory demands, the facts of Dahua suggest that a robust document pre-screening process could be one part of an appropriate risk mitigation strategy. At the CSRC's direction, the Firms ultimately adopted a two-part production process: pre-screening their work papers, and then producing them to the CSRC for approval and ultimate delivery to the SEC.10 For issuers responding to U.S. regulatory requests for China-based data, their principal challenge may lie in the second step: identifying a Chinese regulator (like the CSRC) that has jurisdictional coverage, an ongoing cooperation agreement with the relevant U.S. agency, and the willingness to authorize the production of pre-screened materials.11 Accordingly, the level of protection that U.S. issuers can derive from adopting an internal pre-screening process may diminish in the absence of a Chinese regulator with appropriate pre-production approval authority.

Notwithstanding this limitation, the evidence presented by the Dahua Firms describe several iterations of a protocol for the pre-production screening of auditor work papers for state secrets and other sensitive materials.12 Taken together, these descriptions sketch out a four step pre-screening procedure that could be implemented by companies as a risk-mitigation effort in processing their own Chinese data (whether for government production or internal investigations).

  • Retain Competent Chinese Counsel: in each iteration of the protocol, the CSRC instructed the Firms to retain Chinese counsel. In some cases the attorneys performed the document review, in some cases counsel was part of a review team that included the accountants, while in other cases the attorneys simply reviewed (or certified) the results of the accountants' analysis.
  • Conduct a Document Review: the review team, however constituted, then analyzed the documents to identify any ''state secrets or other sensitive information.''13 According to testimony presented in Dahua, state secrets were ''scattered throughout'' the work papers, and included ''technology know-how'' and ''non-public Chinese 'governance policy.' '' However, state secrets ''were not, 'in general,' found in bank confirmations, supplier confirmations, customer confirmations, bank statements, financial books and records, or [the auditor's] findings.''14 The CSRC appeared to accept a variety of analytical methods, including both page-by-page manual reviews and the use of computerized key word searches.
  • Create a Withholding Log: in at least one iteration of the CSRC protocol, the Firm prepared a spreadsheet of the documents that were to be withheld from production to the SEC.15 Preparing a withholding log makes good sense, as it can be used in future regulatory discussions regarding document productions, as well as creating a solid record of the review procedures followed and the analysis conducted by the company.
  • Create a Redacted Set of Documents for Production: each Firm created a production set of documents, redacted as agreed to by the CSRC. The CSRC cautioned the Firms that they should use ''sound judgment'' in redacting the materials, and not withhold information ''because it contains matter that would cast the accounting firm in a bad light.''16 Companies adopting an internal pre-screening process should also heed this admonition—document over-redaction can damage credibility and sow regulatory suspicion that the screening process is designed to obstruct government inquiry rather than maintain legitimate privileges. The CSRC screening process should feel familiar to any attorney who has performed a pre-production attorney-client privilege review in the U.S. The challenge here, however, is to accurately identify materials containing Chinese state secrets or other sensitive information and ensure appropriate redaction or withholding. Clearly, retaining competent U.S. and Chinese counsel is the first step in developing appropriate prescreening procedures.

Other Issues for Consideration

Dahua raises at least three other issues for U.S. public companies to consider. First, issuers need to understand how their auditor's Chinese affiliate will respond to an SEC request for their work papers—well before the request arrives. For example, in negotiating engagement letters, companies should determine whether their auditor is required to notify them of such requests, and whether the company can obtain indemnification from the U.S. audit firm if its Chinese affiliate fails to produce materials to U.S. authorities or violates foreign laws in making such a production.

Second, companies resolving SEC and other government enforcement matters should consider whether they might be required to produce Chinese data in the future under ongoing cooperation obligations. Compliance with a blanket commitment to cooperate may not be easy or legal under all circumstances. Counsel should attempt to include qualifying language that adequately addresses potentially-conflicting foreign laws, particularly if the client operates in China.17

Finally, issuers should anticipate and proactively address the potential collateral consequences of the ongoing involvement of the Dahua Firms in their audited financials, especially on the SEC staff's treatment of issuers' securities filings. Issuers' efforts should include reviewing their effective registration statements or planned securities offering filings for additional disclosure on the risks to investors of the imposition of the Dahua ban,18 preparing for the use of alternative auditors (including drafting interim reports for notification of a change in auditors), and reviewing other commitments relating to audited financial statements and maintaining public company status (e.g., listing agreements, bank and bond covenants, filings with rating agencies).

Conclusion

The focus of U.S. authorities on issuers' China operations will continue to generate information requests for data located in that market. But responding to such requests poses real risks. No pre-screening process or internal procedure can prevent a company from being accused of violating China's State Secrets Law, it can only mitigate the risk. And given the size and scope of China's myriad administrative and regulatory agencies, it is impossible to anticipate the reaction of every Chinese agency to a U.S. company's direct production of China-based data to U.S. authorities using the prescreening procedures described in Dahua. On the U.S. side, at least some regulators have recognized that conflicting foreign laws may raise legitimate controversies that should be addressed in a responsible fashion.19

The Dahua case, however, suggests that the SEC ultimately will be unforgiving of a U.S. issuer's failure to produce documents on the grounds of incompatible Chinese law.

Footnotes

1 In re BDO China Dahua CPA Co., Ltd., et al., Initial Decision Release No. 553, Administrative Proceeding File Nos. 3-14872, 3-15116, 102 (Jan. 22, 2014). Deloitte LLP's Chinabased affiliate was the subject of a separate, earlier administrative proceeding. In re Deloitte Touche Tohmatsu Certified Public Accountants Ltd., Exchange Act Release No. 66948, Administrative Proceeding File Nos. 3-14872 (May 9, 2012) (''DTTC''). The two proceedings were consolidated by the ALJ (collectively ''Dahua''). The four other Firms were affiliated with BDO, Ernst & Young LLP, KPMG LLP and PricewaterhouseCoopers LLP.

2 See Dahua, supra note 1, at 7 (noting Chinese auditor's citations to ''Article 21 of the Law on Guarding States Secrets of China . . . and to Article 22 of Measures for Implementation of the State Secrets Law'').

3 Id. at 105.

4 The Dahua decision is narrowly premised on the Firms' obligations under SOX § 106(e). The SEC claimed that the five Firms – as ''foreign public accounting firms'' under SOX § 106(g) – had violated SOX § 106(e) by their ''willful refusal to comply'' with the SEC's requests for audit work papers.

5 The CSRC, a ministry-level unit directly under China's State Council that regulates China's securities and futures markets, has regulatory authority over public company auditing firms in China, including the Dahua Firms. About CSRC, CHINA SEC. REGULATION COMM'N, http://www.csrc.gov.cn/pub/csrc_en/about/ (last visited Feb. 14, 2014).

6 Dahua, supra note 1, at 44.

7 Even Chinese officials face opacity in making state secrets determinations. Although a ''clarification'' of the State Secrets Law was recently released, the guidance suggests wide latitude in making such determinations, while emphasizing that officials who reveal too much will be ''dealt with according to law.'' See Richard Silk, China's Secret Anti-Secrecy Act, WALL ST. J., CHINA (Feb. 3, 2014, 9:36 PM), http://blogs.wsj.com/chinarealtime/2014/02/03/chinas-secret-anti-secrecy-act/.

8 The Firms argued that the SEC should have used SOX § 106 (f), which permits the SEC to allow foreign public accounting firms to meet production obligations ''through alternative means, such as through foreign counterparts of the Commission. . .'' Dahua at 98 -100.

9 The Firms have indicated that they will appeal the decision. Alan Katz, China Auditors Barred for Six Months for Blocking SEC, BLOOMBERG PERS. FIN., Jan 23, 2014, available at http://www.bloomberg.com/news/2014-01-22/china-auditorsbarred-for-six-months-for-not-aiding-sec-probes.html.

10 In a separate SEC subpoena enforcement action against Deloitte's Chinese affiliate, the affiliate used this protocol in connection with its production to the SEC through the CSRC. Dahua at 38. The SEC ultimately dismissed this action once the CSRC had completed its delivery of the work papers to the SEC. See Joint Motion to Dismiss without Prejudice, SEC v. Deloitte Touche Tohmatsu CPA Ltd., 1:11-mc-00512, (D.D.C. Jan. 27, 2014). To date, it appears that the Firms and/or the CSRC are still working on the Dahau-related productions, as the SEC has not yet dismissed that proceeding.

11 The CSRC has jurisdiction over Chinese public companies and public accounting firms, which provided the Dahua Firms with a relatively clear regulatory pathway. For U.S. issuers whose Chinese subsidiary is a private company, the likeliest relevant regulator of the subsidiary is China's State Administration of Industry and Commerce. This agency currently does not have a cooperation agreement in place with the SEC, although it has executed an MOU with the U.S. Department of Justice and the U.S. Federal Trade Commission with respect to antitrust matters (available at http://www.justice.gov/atr/public/international/docs/273310a.pdf.). Moreover, even if an appropriate agency and pathway is identified, U.S. companies may be reluctant to voluntarily submit information to Chinese regulators for pre-production approval, when the only triggering event is a U.S. government information request. The recent detentions in China of GlaxoSmithKline executives and U.S. and U.K. nationals in connection with corruption probes that overlap with U.S.-based Foreign Corrupt Practices Act (''FCPA'') investigations suggest one species of legitimate concern.

12 According to the evidence introduced in Dahua, between February 2012 and June 2013 the CSRC provided several variations or iterations of the pre-screening protocol to the Firms, both individually and in group meetings. See Dahua, supra note 1, at 19, 30, 37-38.

13 Id. at 30.

14 Id. at 37.

15 Id. at 37.

16 Id. at 38.

17 See, e.g., In re Total, S.A, Exchange Act Release No. 6954, Administrative Proceeding File No. 3-15338, 6 -7 (May 29, 2013) (addressing potential data protection issues). Cf., Deferred Prosecution Agreement, U.S. Sec. and Exch. Comm'n and Tenaris S.A., ¶ 3(a) (May 17, 2011), available at http://www.sec.gov/news/press/2011/2011-112-dpa.pdf (agreeing to produce all non-privileged materials ''wherever located'').

18 See, e.g., JD.com, Inc., Registration Statement Under the Securities Act of 1933 (Form F-1) 36 – 37 (Jan. 30, 2014) (Risk Factors disclosure includes upholding of Dahua bar, which could result in its financial statements being ''determined to not be in compliance with the requirements of the Exchange Act'' and could ''lead to the delay or abandonment of this offering, delisting of our Class A ordinary shares from the NYSE/ NASDAQ Global Market or deregistration from the SEC, or both, which would substantially reduce or effectively terminate the trading of our ADSs in the United States'').

19 For example, in the context of cross-border FCPA matters, the U.S. Department of Justice has credited companies for producing materials in compliance with conflicting foreign laws. See, e.g., Department of Justice Sentencing Memorandum, United States v. Siemens Aktiengesellschaft, No. 1:08-cr- 00367-RJL, at 21 (D.D.C. Dec. 12, 2008). (''Siemens has worked hard to take necessary steps, and where necessary, obtain approval from foreign authorities, to make the documents available to the Department and the SEC as promptly as possible and in compliance with relevant data privacy laws and other legal restrictions. Siemens extensive efforts . . . have been exemplary and serve as a model to other multi-national companies seeking to cooperate with law enforcement authorities.'')

Originally published in the Securities Regulation & Law Report, 46 SRLR 610, 03/31/2014.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Registration
Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:
  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.
  • Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.
    If you do not want us to provide your name and email address you may opt out by clicking here
    If you do not wish to receive any future announcements of products and services offered by Mondaq you may opt out by clicking here

    Terms & Conditions and Privacy Statement

    Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

    Use of www.mondaq.com

    You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

    Disclaimer

    Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

    The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

    Registration

    Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

    • To allow you to personalize the Mondaq websites you are visiting.
    • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
    • To produce demographic feedback for our information providers who provide information free for your use.

    Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

    Information Collection and Use

    We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

    We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

    Mondaq News Alerts

    In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

    Cookies

    A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

    Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

    Log Files

    We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

    Links

    This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

    Surveys & Contests

    From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

    Mail-A-Friend

    If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

    Emails

    From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

    *** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .

    Security

    This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

    Correcting/Updating Personal Information

    If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

    Notification of Changes

    If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

    How to contact Mondaq

    You can contact us with comments or queries at enquiries@mondaq.com.

    If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.

    By clicking Register you state you have read and agree to our Terms and Conditions