What is the N
Atwell_Suites Franchise · 2025 FDDAnswer from 2025 FDD Document
N. Anti-Terrorism, Anti-Bribery and Trade Sanctions Compliance.
- (1) Licensee represents, warrants and covenants that neither it nor any Entity or individual having a direct or indirect ownership interest in it, nor any Guarantor, nor any of Licensee's Affiliates nor any officer, director, employee, member, partner or shareholder of any of the foregoing, has been or is now:
- (a) directly or indirectly owned or controlled by the government of any nation subject to trade sanctions or embargoes imposed by any of the Sanctioning Bodies (as defined below in sub-paragraph (4));
- (b) acting on behalf of any government of any nation subject to the trade sanctions or embargoes imposed by any of the Sanctioning Bodies;
- (c) identified by any of the Sanctioning Bodies as a Prohibited Person; and
- (d) in violation of any applicable law relating to anti-money laundering, anti-terrorism, antibribery, trade sanctions or embargoes, narcotics, illegal immigration or human tracking, including without limitation, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, the US Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (US Patriot Act) and related regulations and executive orders related to the foregoing laws (the "Relevant Laws").
- (2) Licensee further warrants and represents and covenants that:
- (a) Licensee, any Guarantor and any Person having a direct or indirect ownership in Licensee will comply with the Relevant Laws; and
- (b) all individuals authorized to represent Licensee in carrying out its obligations under this License are eligible under applicable United States immigration laws to travel to the United States for training or any other purpose in carrying out Licensee's obligations under this License.
- (3) For the purposes of this paragraph 13.N., "Person" means any individual, corporation, partnership, joint venture, limited liability company, estate, trust, unincorporated association, any national, provincial, state, county or municipal government or any bureau, office, department or agency thereof and any fiduciary acting in an agency capacity on behalf of any of the foregoing. "Prohibited Person" means any person identified by Her Majesty's Treasury of the United Kingdom ("UK"), by the Office of Foreign Assets Control of the Department of the Treasury of the United States ("US") as a "specially designated national" or otherwise subject to sanction by the European Union ("EU") and/or the United Nations ("UN"), (collectively, "Sanctioning Bodies"), or any other Person with whom IHG, or any of its Affiliates, is otherwise prohibited from transacting business.
Source: Item 23 — Receipts (FDD pages 99–486)
What This Means (2025 FDD)
Based on the 2025 Atwell Suites Franchise Disclosure Document, Section 13.N discusses compliance with anti-terrorism, anti-bribery, and trade sanctions. This section includes representations, warranties, and covenants that the franchisee (Licensee), any entity or individual with ownership interest, any guarantor, affiliates, or any officer, director, employee, member, partner, or shareholder has not been involved in activities related to governments under trade sanctions, acting on behalf of such governments, identified as a Prohibited Person by sanctioning bodies, or violated laws related to anti-money laundering, anti-terrorism, anti-bribery, trade sanctions, narcotics, illegal immigration, or human tracking.
The Atwell Suites franchisee must warrant and represent that they will comply with all relevant laws and that all individuals authorized to represent the franchisee are eligible under United States immigration laws to travel to the United States for training or any other purpose related to fulfilling the obligations under the license.
For the purposes of this section, the FDD defines "Person" broadly to include individuals, corporations, partnerships, and governmental entities. It also defines "Prohibited Person" as anyone identified by sanctioning bodies such as Her Majesty's Treasury of the UK, the Office of Foreign Assets Control of the US Department of the Treasury, the European Union, or the United Nations, or any other person with whom IHG or its affiliates are prohibited from transacting business.