What constitutes grounds for immediate termination of the Anago subfranchise agreement related to Anti-Terrorism Laws?
Anago Franchise · 2025 FDDAnswer from 2025 FDD Document
Subfranchisor shall comply with, and assist Franchisor to the fullest extent possible in Franchisor's efforts to comply with, the Anti-Terrorism Laws (as defined below). Subfranchisor shall not hire nor have any dealings with any person listed on the SDN List, as it may be modified from time to time. Subfranchisor is solely responsible for ascertaining what actions must be taken by Subfranchisor to comply with all Anti-Terrorism Laws. Subfranchisor specifically acknowledges and agrees that Subfranchisor's indemnification obligations under this Agreement pertain to Subfranchisor's obligations under this Section. Any misrepresentation by Subfranchisor under this Section, or any violation of any Anti-Terrorism Laws by Subfranchisor, Subfranchisor's owners, principals or employees, shall constitute grounds for immediate termination of this Agreement and any other agreement Subfranchisor has entered into with Franchisor or its Affiliates. As used herein, "Anti-Terrorism Laws" means Executive Order 13224 issued by the President of the United States, the Terrorism Sanctions Regulations (Title 31, Part 595 of the U.S. Code of Federal Regulations), the Foreign Terrorist Organizations Sanctions Regulations (Title 31, Part 597 of the U.S. Code of Federal Regulations), the Cuban Assets Control Regulations (Title 31, Part 515 of the U.S. Code of Federal Regulations), the USA PATRIOT ACT, and all other present and future federal, state and local laws, ordinances, regulations, policies, lists and any other requirements of any Governmental Authority (including, without limitation, The United States Department of Treasury Office of Foreign Assets Control) addressing or in any way relating to terrorist acts and acts of war.
Source: Item 23 — RECEIPTS (FDD pages 62–298)
What This Means (2025 FDD)
According to Anago's 2025 Franchise Disclosure Document, a subfranchisee's misrepresentation or violation of Anti-Terrorism Laws constitutes grounds for immediate termination of the Anago Subfranchise Agreement. This includes any other agreements the subfranchisee has with Anago or its affiliates.
The Anti-Terrorism Laws, as defined in the FDD, encompass a range of regulations, including Executive Order 13224, the Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations, the Cuban Assets Control Regulations, the USA PATRIOT ACT, and all other federal, state, and local laws related to terrorist acts and acts of war. It also includes any requirements from governmental authorities such as the United States Department of Treasury Office of Foreign Assets Control.
This means that an Anago subfranchisee must comply with all Anti-Terrorism Laws and must not hire or have any dealings with individuals or entities listed on the SDN (Specially Designated Nationals and Blocked Persons) List. The subfranchisee is solely responsible for understanding and adhering to these laws. Failure to do so, whether through misrepresentation or violation, can result in the immediate termination of the franchise agreement. This provision highlights the importance Anago places on compliance with anti-terrorism regulations and the serious consequences for non-compliance.