What is the Cinnaholic franchisee's sole responsibility regarding compliance with Anti-Terrorism Laws?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
- (v) Developer is solely responsible for ascertaining what actions it must take to comply with the Anti-Terrorism Laws.
Source: Item 23 — RECEIPT (FDD pages 62–269)
What This Means (2025 FDD)
According to the 2025 Cinnaholic Franchise Disclosure Document, the franchisee, referred to as the 'Developer,' is solely responsible for determining the actions necessary to comply with Anti-Terrorism Laws. This means that Cinnaholic franchisees must independently ascertain and implement all measures required to adhere to these laws.
Cinnaholic defines "Anti-Terrorism Laws" to include 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. Franchisees must ensure their operations, employees, and related parties are not in violation of these laws.
Furthermore, the Cinnaholic franchisee must certify that they, their employees, agents, bankers, affiliates, and anyone associated with them are not listed in the Annex to Executive Order 13224, and they must not hire or retain anyone listed in the Annex. Any misrepresentation or violation of these laws by the franchisee or their associates can lead to immediate termination of the franchise agreement with Cinnaholic.