What is the Cinnaholic franchisee's responsibility in assisting the franchisor with complying with Anti-Terrorism Laws?
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, franchisees and their owners must comply with and assist Cinnaholic to the fullest extent possible in Cinnaholic's efforts to comply with Anti-Terrorism Laws. This includes certifying, representing, and warranting 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 the Anti-Terrorism Laws. Franchisees must 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 agree not to hire (or retain) any individual listed in the Annex.
"Anti-Terrorism Laws" are defined as 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.
In practical terms, this means a prospective Cinnaholic franchisee must conduct thorough due diligence to ensure they, their business partners, and their employees are not in violation of any anti-terrorism laws or associated with any individuals or entities on restricted lists. Failure to comply with these laws could result in immediate termination of the Franchise Agreement.