Does the Bhc franchise agreement specify any exceptions to the compliance requirements with U.S. Anti-Terrorism laws?
Bhc Franchise · 2025 FDDAnswer from 2025 FDD Document
16.12 Compliance with U.S. Anti-Terrorism and Other U.S. Federal Laws.
- (a) Franchisee certifies that neither it nor any Principal Equity Operators or employees of Franchisee, or anyone else who is associated with Franchisee is not listed in the Annex to Executive Order 13224 (available at http://treasury.gov/offices/enforcement/ofac/sanctions/terrorism.html).
Franchisee covenants not to hire or have any dealings with a person listed in the Annex.
Franchisee certifies that it has no knowledge or information that, if generally known, would result in Franchisee, the Principal Equity Operators, employees, or anyone associated with Franchisee being listed in the Annex to Executive Order 13224.
Franchisee and each of the Principal Equity Operators will comply with and assist Franchisor as much as possible in Franchisor's efforts to comply with the Anti- Terrorism Laws (as defined below).
In connection with such compliance, Franchisee certifies, represents, and warrants that none of Franchisee's respective property or interests is subject to being "blocked" under any of the Anti-Terrorism Laws and that Franchisee and the Principal Equity Operators are not otherwise in violation of any of the Anti-Terrorism Laws.
Franchisee is solely responsible for ascertaining what actions must be taken by Franchisee to comply with all such Anti-Terrorism Laws.
Franchisee specifically acknowledges and agrees that its indemnification responsibilities as provided in this Agreement also pertain to its obligations under this section 16.12.
Any misrepresentation by Franchisee under this section 16.12 or any violation of the Anti-Terrorism Laws by Franchisee, any of the Principal Equity Operators, or employees will constitute grounds for immediate termination of this Agreement and any other agreement Franchisee executed with Franchisor or one of Franchisor's Affiliates. "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.
Source: Item 23 — Receipts (FDD pages 52–230)
What This Means (2025 FDD)
According to Bhc's 2025 Franchise Disclosure Document, there are no explicit exceptions to the compliance requirements with U.S. Anti-Terrorism laws. The franchise agreement emphasizes strict adherence to these laws. Both the franchisee and their Principal Equity Operators must comply with all Anti-Terrorism Laws. Franchisees must also assist Bhc in their compliance efforts as much as possible.
The agreement requires franchisees to certify that neither they, their Principal Equity Operators, nor anyone associated with them is listed in the Annex to Executive Order 13224, which lists known terrorists. Franchisees must also promise not to hire or deal with anyone on that list. Furthermore, franchisees must certify they have no knowledge that would lead to themselves or associated parties being added to the Annex.
Bhc holds franchisees solely responsible for understanding and adhering to all Anti-Terrorism Laws. Any misrepresentation or violation of these laws by the franchisee, their Principal Equity Operators, or employees constitutes grounds for immediate termination of the franchise agreement and any other agreements with Bhc or its affiliates. This strict stance underscores the importance Bhc places on compliance with these laws and the potential consequences of non-compliance.