What activities are prohibited for Bhc franchisees and Principal Equity Operators regarding money laundering?
Bhc Franchise · 2025 FDDAnswer from 2025 FDD Document
(b) Neither Franchisee nor any Principal Equity Operator conducts any activity, or has failed to conduct any activity, if such action or inaction constitutes a money laundering crime, including any money laundering crime prohibited under any applicable Anti-Terror Legislation.
(c) Neither Franchisee nor any Principal Equity Operator nor any employee of either is named as a "Specially Designated National" or "Blocked Person" as designated by the U.S. Department of the Treasury's Office of Foreign Assets Control and published at www.treas.gov/offices/enforcement/ofac/sdn/. Franchisee acknowledges that Franchisee is not directly or indirectly owned or controlled by the government of any country that is subject to an embargo imposed by the United States of America, nor does Franchisee or any Principal Equity Operator act directly or indirectly on behalf of the government of any country that is subject to an embargo imposed by the United States of America. Franchisee agrees that Franchisee will notify Franchisor in writing immediately of the occurrence of any event that renders the foregoing representations and warranties of this section 16.12 incorrect.
Source: Item 23 — Receipts (FDD pages 52–230)
What This Means (2025 FDD)
According to Bhc's 2025 Franchise Disclosure Document, franchisees and Principal Equity Operators are prohibited from engaging in activities that constitute money laundering crimes. Specifically, they must not conduct any activity, nor fail to conduct any activity, if such action or inaction violates anti-money laundering laws. This includes any money laundering crime prohibited under applicable Anti-Terror Legislation.
Furthermore, neither the franchisee nor any Principal Equity Operator or their employees can be named as a "Specially Designated National" or "Blocked Person" by the U.S. Department of the Treasury's Office of Foreign Assets Control. Franchisees must also affirm that they are not directly or indirectly owned or controlled by the government of any country subject to a U.S. embargo, nor acting on behalf of such a government.
Bhc requires franchisees to notify them immediately in writing if any event occurs that would make these representations incorrect. This is to ensure compliance with various federal regulations, including the Bank Secrecy Act, the Foreign Terrorist Organizations Sanctions Regulations, the Cuban Assets Control Regulations, the USA PATRIOT Act, and any other requirements related to terrorist acts and acts of war.