What U.S. Presidential Executive Order is specifically referenced in the Cinnaholic definition of 'Anti-Terrorism Laws'?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
- (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, the brand's definition of "Anti-Terrorism Laws" specifically references Executive Order 13224, issued by the President of the United States. This order is included within a broader definition that also encompasses 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 related to terrorist acts and/or acts of war.
Cinnaholic requires its developers (franchisees) and their owners to comply with these Anti-Terrorism Laws and assist Cinnaholic in its own compliance efforts. Franchisees must certify that none of their property or interests are subject to being "blocked" under these laws and that they are not in violation of any of them. They also certify that they, their employees, agents, bankers, or affiliates are not listed in the Annex to Executive Order 13224 and agree not to hire anyone listed in the Annex.
Furthermore, Cinnaholic franchisees must ensure they have no knowledge or information that could lead to themselves or anyone associated with them being listed in the Annex to Executive Order 13224. The franchisee is solely responsible for understanding and adhering to these Anti-Terrorism Laws. Failure to comply or any misrepresentation in this area can lead to immediate termination of the Franchise Agreement, highlighting the importance Cinnaholic places on adherence to these regulations.