What is the Cinnaholic franchisee's responsibility in determining the actions needed to comply with Anti-Terrorism Laws?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
(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 franchisee is solely responsible for determining the actions needed to comply with Anti-Terrorism Laws. This means that Cinnaholic franchisees must independently ascertain and implement all measures necessary to adhere to these laws. These laws include Executive Order 13224, the Terrorism Sanctions Regulation, the Foreign Terrorist Organizations Sanctions Regulations, the Cuban Assets Control Regulations, and the USA PATRIOT Act, along with any other relevant federal, state, and local regulations.
This requirement places a significant responsibility on the franchisee, as non-compliance can lead to severe consequences. The franchisee also acknowledges that their indemnification responsibilities, as detailed in Section 18 of the agreement, extend to their obligations under this section concerning Anti-Terrorism Laws. This means the franchisee is responsible for covering any losses or damages resulting from their failure to comply with these laws.
Furthermore, any misrepresentation or violation of Anti-Terrorism Laws by the franchisee, their owners, agents, bankers, employees, or affiliates constitutes grounds for immediate termination of the Franchise Agreement and any other agreements with Cinnaholic or its affiliates. This underscores the critical importance of understanding and adhering to these laws to maintain the franchise agreement and avoid potential legal and financial repercussions.