What certification do Cinnaholic Developers and their owners make regarding Executive Order 13224?
Cinnaholic Franchise · 2025 FDDAnswer 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.)
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, including Executive Order 13224. Specifically, they certify, represent, and warrant that none of their property or interests is subject to being "blocked" under any anti-terrorism laws and that they are not otherwise in violation of any of these laws. They also certify that neither they, their employees, agents, bankers, affiliates, nor anyone associated with them is listed in the Annex to Executive Order 13224. Furthermore, they agree not to hire or retain anyone listed in the Annex.
This requirement means that prospective Cinnaholic developers and their owners must conduct due diligence to ensure they are not in violation of any anti-terrorism laws and that none of their assets are blocked under these laws. They must also ensure that their employees and affiliates are not listed in the Annex to Executive Order 13224. Failure to comply with these laws can result in immediate termination of the Development Agreement.
The Cinnaholic FDD also defines "Anti-Terrorism Laws" to include 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, ordinances, regulations, policies, lists, and any other requirements of any governmental authority relating to terrorist acts and/or acts of war. The developer is solely responsible for understanding and adhering to these laws.
This is a standard clause in many franchise agreements to ensure that the franchise system is not associated with any individuals or entities involved in terrorism. Prospective franchisees should carefully review these requirements and consult with legal counsel to ensure compliance.