Is Bhc Franchisee required to assist Franchisor in complying with 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, franchisees are required to assist Bhc in complying with anti-terrorism laws. Franchisees must ensure that neither they, their Principal Equity Operators, employees, nor anyone associated with them is listed in the Annex to Executive Order 13224. Franchisees also covenant not to hire or have any dealings with individuals listed in the Annex.
Furthermore, franchisees must certify they have no knowledge or information that would lead to themselves, their Principal Equity Operators, employees, or anyone associated with them being listed in the Annex to Executive Order 13224. Franchisees and their Principal Equity Operators must comply with and assist Bhc as much as possible in Bhc's efforts to comply with Anti-Terrorism Laws. Franchisees must also certify, represent, and warrant that their property or interests are not subject to being "blocked" under any of the Anti-Terrorism Laws and that they and their Principal Equity Operators are not in violation of any Anti-Terrorism Laws.
Franchisees are solely responsible for determining the actions needed to comply with all Anti-Terrorism Laws. They also acknowledge that their indemnification responsibilities extend to their obligations under this section. Any misrepresentation or violation of Anti-Terrorism Laws by the franchisee, their Principal Equity Operators, or employees can result in immediate termination of the franchise agreement and any other agreements with Bhc or its affiliates. The Anti-Terrorism Laws 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.