What are the consequences if a Cinnaholic franchisee or their owners, agents, bankers, employees, or affiliates violate Anti-Terrorism Laws?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
- (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 the 2025 Cinnaholic Franchise Disclosure Document, a violation of Anti-Terrorism Laws by a Cinnaholic franchisee or their owners, agents, bankers, employees, and affiliates constitutes grounds for immediate termination of the Franchise Agreement. This also applies to any other agreement the franchisee has entered into with Cinnaholic or its affiliates.
The FDD specifies that franchisees and their owners must comply with Anti-Terrorism Laws and assist Cinnaholic in its compliance efforts. Franchisees must certify that their property and interests are not subject to being "blocked" under these laws and that they are not in violation of any Anti-Terrorism Laws. These laws include Executive Order 13224, the Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations, the Cuban Assets Control Regulations, the USA PATRIOT Act, and all other relevant federal, state, and local regulations.
Furthermore, franchisees must certify that none of their employees, agents, bankers, affiliates, or anyone associated with them is listed in the Annex to Executive Order 13224, and they must not hire or retain anyone listed in the Annex. The Annex, which can be accessed on the internet, contains a list of individuals and entities associated with terrorism. This requirement places a significant responsibility on the franchisee to conduct thorough due diligence and ensure compliance with these complex and evolving regulations. Failure to comply can result in the immediate loss of the franchise and all associated investments.