Which item in the Bhc Disclosure Document discusses the franchisee's obligation to comply with anti-terrorism and other federal laws?
Bhc Franchise · 2025 FDDAnswer from 2025 FDD Document
[Item 23: Receipts]
16.11 Counterparts.
This Agreement may be executed in multiple copies, each of which will be deemed to be an original, and all of which together will be deemed to be one and the same instrument.
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 9 — Franchisee's Obligations (FDD pages 28–29)
What This Means (2025 FDD)
According to Bhc's 2025 Franchise Disclosure Document, Item 23 discusses the franchisee's obligation to comply with U.S. Anti-Terrorism and other U.S. Federal Laws. Specifically, section 16.12 within Item 23 details these obligations. This section emphasizes that the franchisee must certify they, their Principal Equity Operators, and employees are not listed in the Annex to Executive Order 13224, which is available at a provided government website. The franchisee also agrees not to engage with individuals listed in the Annex.
Bhc requires franchisees to actively comply with anti-terrorism laws and assist Bhc in its compliance efforts. Franchisees must ensure that their property and interests are not subject to being "blocked" under any Anti-Terrorism Laws and that they are not in violation of these laws. The franchisee bears the responsibility for determining the necessary actions to comply with all Anti-Terrorism Laws.
Furthermore, the document states that any misrepresentation or violation of Anti-Terrorism Laws by the franchisee, its Principal Equity Operators, or employees can lead to immediate termination of the franchise agreement and any other agreements with Bhc or its affiliates. The document defines "Anti-Terrorism Laws" to include Executive Order 13224, Terrorism Sanctions Regulations, Foreign Terrorist Organizations Sanctions Regulations, 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.