Who is responsible for determining the actions needed to comply with Anti-Terrorism Laws for a Cinnaholic franchise?

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 each Cinnaholic franchisee must independently ascertain and implement the necessary measures to adhere to all applicable federal, state, and local laws, ordinances, regulations, policies, and requirements related to terrorist acts and acts of war. These laws include, but are not limited to, Executive Order 13224, the Terrorism Sanctions Regulation, the Foreign Terrorist Organizations Sanctions Regulations, the Cuban Assets Control Regulations, and the USA PATRIOT Act.

This responsibility includes ensuring that neither the franchisee, their owners, employees, agents, bankers, affiliates, nor anyone associated with them is listed in the Annex to Executive Order 13224, which can be accessed on the internet. The franchisee must also certify that they have no knowledge or information that would lead to any of these parties being listed in the Annex.

The FDD emphasizes that the franchisee's indemnification responsibilities, as outlined in Section 18 of the agreement, extend to their obligations under this section concerning Anti-Terrorism Laws. Any misrepresentation or violation of these laws by the franchisee or their associated parties constitutes grounds for immediate termination of the franchise agreement and any other agreements with Cinnaholic or its affiliates. This places a significant legal and financial burden on the franchisee to ensure full compliance with all Anti-Terrorism Laws.