What is the definition of 'Anti-Terrorism Laws' in the Cinnaholic agreement?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
[Item 23: RECEIPT]
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, "Anti-Terrorism Laws" are defined as 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.
Cinnaholic requires that the developer and its owners comply with these laws and assist Cinnaholic in complying with them to the fullest extent possible. The developer must certify that none of their property or interests is subject to being "blocked" under these laws and that they are not in violation of any of these laws. They also certify that none of their employees, agents, bankers, affiliates, or anyone associated with them is listed in the Annex to Executive Order 13224 and agree not to hire anyone listed in the Annex.
Failure to comply with Anti-Terrorism Laws or any misrepresentation related to these laws can result in immediate termination of the Cinnaholic agreement and any other agreements the developer has with Cinnaholic. The developer is solely responsible for understanding and adhering to these laws. This places a significant responsibility on the franchisee to ensure they, their business, and all associated parties are in full compliance with all applicable anti-terrorism regulations, which can be complex and subject to change.