For Bhc franchises, is a Master Franchisee or Principal Equity Operator prohibited from being named as a 'Specially Designated National' or 'Blocked Person' by the U.S. Department of the Treasury's Office of Foreign Assets Control?
Bhc Franchise · 2025 FDDAnswer from 2025 FDD Document
- (b) Neither Master 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 Master 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/. Master Franchisee acknowledges that Master 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 Master 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. Master Franchisee agrees that Master 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, both Master Franchisees and Principal Equity Operators are prohibited from being named as a "Specially Designated National" or "Blocked Person" by the U.S. Department of the Treasury's Office of Foreign Assets Control. Bhc emphasizes compliance with anti-terrorism laws and regulations. This requirement ensures that no one involved in the ownership or operation of the franchise is associated with entities or individuals blacklisted by the U.S. government. The list of Specially Designated Nationals and Blocked Persons is published at www.treas.gov/offices/enforcement/ofac/sdn/.
Bhc also requires that neither the Master Franchisee nor any Principal Equity Operator conduct any activity, or fail to conduct any activity, that constitutes a money laundering crime, including any money laundering crime prohibited under applicable Anti-Terror Legislation. The Master Franchisee must also acknowledge that they are 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 do they act directly or indirectly on behalf of such a government.
Furthermore, the Master Franchisee must notify Bhc in writing immediately if any event occurs that would render these representations and warranties incorrect. Any misrepresentation or violation of anti-terrorism laws by the Master Franchisee, Principal Equity Operators, or employees constitutes grounds for immediate termination of the franchise agreement. This stringent requirement reflects the importance Bhc places on adhering to legal and ethical standards, and the potential consequences of non-compliance for the franchisee.