What does the Cinnaholic franchise agreement require franchisees and their owners to certify regarding the Annex to Executive Order 13224?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
- (iii) Franchisee 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.
Franchisee 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) Franchisee certifies that it has no knowledge or information that, if generally known, would result in (a) Franchisee, (b) Franchisee's owners, employees, agents, bankers or affiliates or (c) anyone associated with Franchisee to be listed in the Annex to Executive Order 13224.
(v) Franchisee is solely responsible for ascertaining what actions it must take to comply with the Anti-Terrorism Laws, and Franchisee specifically acknowledges and agrees that Franchisee's indemnification responsibilities set forth in Section 18 above of this Agreement pertain to Franchisee's obligations under this Section 42.2.
(vi) Any misrepresentation under this Section or any violation of the Anti-Terrorism Laws by Franchisee or Franchisee's owners, agents, bankers, employees and affiliates shall constitute grounds for immediate termination of this Agreement and any other agreement Franchisee has entered with Franchisor or an affiliate of Franchisor, in accordance with Section 21.2(xvi) above.
Source: Item 22 — CONTRACTS (FDD pages 61–62)
What This Means (2025 FDD)
According to Cinnaholic's 2025 Franchise Disclosure Document, the franchise agreement includes clauses related to compliance with anti-terrorism laws. Specifically, Cinnaholic requires that franchisees and their owners certify that they, their employees, agents, bankers, affiliates, or anyone associated with them are not listed in the Annex to Executive Order 13224.
Furthermore, Cinnaholic franchisees must certify that they have no knowledge or information that would result in themselves or any of their associated parties being listed in the Annex to Executive Order 13224. Franchisees are solely responsible for understanding and adhering to all applicable anti-terrorism laws.
Any misrepresentation or violation of these anti-terrorism laws by the franchisee or their associated parties constitutes grounds for immediate termination of the Cinnaholic franchise agreement and any other agreements with Cinnaholic or its affiliates. This places a significant responsibility on the franchisee to conduct thorough due diligence and maintain ongoing compliance.