factual

What agreement do Cinnaholic Developers and their owners make regarding compliance with Anti-Terrorism Laws?

Cinnaholic Franchise · 2025 FDD

Answer from 2025 FDD Document

32.2. Anti-Terrorism Laws.

  • (i) Developer and its owners agree to comply with and/or to assist Franchisor to the fullest extent possible in Franchisor's efforts to comply with Anti-Terrorism Laws. In connection with such compliance, Developer and its owners certify, represent, and warrant that none of their property or interests is subject to being "blocked" under any of the Anti-Terrorism Laws and that Developer and its owners are not otherwise in violation of any of the Anti-Terrorism Laws.
  • (ii) "Anti-Terrorism Laws" means Executive Order 13224 issued by the President of the United States ("Executive Order 13224"), the Terrorism Sanctions Regulation (Title 31, Part 595 of the U.S. Code of Federal Regulations), the Foreign Terrorist Organizations Sanctions Regulations (Title 31, Part 597 of the U.S. Code of Federal Regulations), the Cuban Assets Control Regulations (Title 31, Part 515 of the U.S. Code of Federal Regulations), the USA PATRIOT Act, and all other present and future federal, state and local laws, ordinances regulations, policies, lists and any other requirements of any governmental authority (including, without limitation, the United States Department of Treasury Office of Foreign Assets Control, and any other government agency with jurisdiction over the parties to this Agreement and/or their actions) addressing or in any way relating to terrorist acts and/or acts of war.
  • (iii) Developer and its owners certify that none of them, their respective employees, agents, bankers, affiliates or anyone associated with them is listed in the Annex to Executive Order 13224. Developer agrees not to hire (or, if already employed, retain the employment of) any individual who is listed in the Annex. (A copy of the Annex can be accessed on the internet at the following address: http://www.treasury.gov/offices/enforcement/ofac/sanctions/terrorism.html.)
  • (iv) Developer certifies that it has no knowledge or information that, if generally known, would result in (a) Developer, (b) Developer's owners, employees, agents, bankers or affiliates or (c) anyone associated with Developer to be listed in the Annex to Executive Order 13224.
  • (v) Developer is solely responsible for ascertaining what actions it must take to comply with the Anti-Terrorism Laws.
  • (vi) Any misrepresentation under this Section or any violation of the Anti-Terrorism Laws by Developer or Developer's owners, agents, bankers, employees and affiliates shall constitute grounds for immediate termination of this Agreement and any other agreement Developer has entered with Franchisor or an affiliate of Franchisor, in accordance with Section 12.2(xiii) above.

Source: Item 23 — RECEIPT (FDD pages 62–269)

What This Means (2025 FDD)

According to Cinnaholic's 2025 Franchise Disclosure Document, Cinnaholic Developers and their owners must comply with Anti-Terrorism Laws. They must also assist Cinnaholic in complying with these laws to the fullest extent possible. As part of this agreement, Developers and their owners must certify, represent, and warrant that none of their property or interests are subject to being "blocked" under any Anti-Terrorism Laws and that they are not in violation of any of these laws.

The term "Anti-Terrorism Laws" includes Executive Order 13224, the Terrorism Sanctions Regulation, 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 or acts of war. Developers and their owners also certify that none of them, their employees, agents, bankers, affiliates, or anyone associated with them is listed in the Annex to Executive Order 13224, and they agree not to hire anyone listed in the Annex.

Furthermore, Cinnaholic Developers must certify that they have no knowledge or information that would result in themselves, their owners, employees, agents, bankers, affiliates, or anyone associated with them being listed in the Annex to Executive Order 13224. Developers are solely responsible for understanding and taking the necessary actions to comply with Anti-Terrorism Laws. Any misrepresentation or violation of these laws by the Developer or related parties can lead to immediate termination of the Development Agreement and any other agreements with Cinnaholic.

Disclaimer: This information is extracted from the 2025 Franchise Disclosure Document and is provided for research purposes only. It does not constitute legal or financial advice. Consult with a franchise attorney before making any investment decisions.