What is the Anago subfranchisor's obligation regarding compliance with 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, the subfranchisor has specific obligations regarding compliance with Anti-Terrorism Laws. The Anago subfranchisor must comply with these laws and assist Anago in its efforts to comply with them to the fullest extent possible. This includes not hiring or dealing with any person listed on the Specially Designated Nationals (SDN) List, which is updated periodically.
The subfranchisor is solely responsible for determining the actions needed to comply with all Anti-Terrorism Laws. The agreement emphasizes that the subfranchisor's indemnification obligations extend to their responsibilities under this section. Any misrepresentation or violation of Anti-Terrorism Laws by the subfranchisor, their owners, principals, or employees, can result in immediate termination of the agreement with Anago.
The Anti-Terrorism Laws, as defined in the FDD, include 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 present and future federal, state, and local laws related to terrorist acts and acts of war. This also encompasses requirements from any Governmental Authority, including the U.S. Department of Treasury Office of Foreign Assets Control. Prospective Anago subfranchisors should carefully review these requirements and ensure they have systems in place to comply.