What actions are specifically prohibited for a Brueggers Bagels franchisee to ensure compliance with the United States Foreign Corrupt Practices Act and the International Money Laundering Abatement and Anti-Terrorist Financing Act?
Brueggers_Bagels Franchise · 2025 FDDAnswer from 2025 FDD Document
You are prohibited from taking any actions that would jeopardize our ability to comply with the United States Foreign Corrupt Practices Act and the International Money Laundering Abatement and Anti-Terrorist Financing Act, otherwise known as the Patriot Act.
Franchisee represents and warrants to Franchisor that neither Franchisee, nor any of its respective affiliates is identified, either by name or an alias, pseudonym or nickname, on the lists of "Specially Designated Nationals" or "Blocked Persons" maintained by the U.S.
Treasury Department's Office of Foreign Assets Control (texts currently available at http://www.treasury.gov/resourcecenter/sanctions/Programs/ Pages/Programs.aspx).
Further, Franchisee represents and warrants that neither it nor any of its affiliates has violated, and agrees not to violate, any law prohibiting corrupt business practices, money laundering or the aid or support of persons or entities who conspire to commit acts of terror against any person, entity or government, including acts prohibited by the U.S.
Patriot Act (text currently available at http://www.epic.org/privacy/terrorism/hr3162.html), U.S.
Executive Order 13224 (text currently available at http://www.treasury.gov/resource-center/sanctions/programs/documents/terror.pdc), or any similar law.
Source: Item 22 — CONTRACTS (FDD page 61)
What This Means (2025 FDD)
According to the 2025 Brueggers Bagels Franchise Disclosure Document, franchisees are prohibited from taking any actions that would jeopardize Brueggers Bagels' ability to comply with the United States Foreign Corrupt Practices Act and the International Money Laundering Abatement and Anti-Terrorist Financing Act, also known as the Patriot Act. This places a responsibility on the franchisee to ensure their business operations do not create any risk of non-compliance for the franchisor with these federal laws.
Furthermore, the franchisee must warrant that neither they nor any of their affiliates are identified on the lists of "Specially Designated Nationals" or "Blocked Persons" maintained by the U.S. Treasury Department's Office of Foreign Assets Control. The franchisee also confirms that they have not violated any laws prohibiting corrupt business practices, money laundering, or support of terrorist activities.
This obligation extends to an agreement not to violate any similar laws, including the U.S. Patriot Act and U.S. Executive Order 13224. These stipulations highlight the importance Brueggers Bagels places on legal and ethical conduct, requiring franchisees to maintain a high standard of compliance to protect both their own business and the franchisor's reputation.