What specific certifications must Cinnaholic franchisees and their owners make regarding compliance with Anti-Terrorism Laws?
Cinnaholic Franchise · 2025 FDDAnswer from 2025 FDD Document
- (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.)
- (iv) Developer certifies that it has no knowledge or information that, if generally known, would result in (a) Developer, (b) Developer's owners, employees, agents, bankers or affiliates or (c) anyone associated with Developer to be listed in the Annex to Executive Order 13224.
- (v) Developer is solely responsible for ascertaining what actions it must take to comply with the Anti-Terrorism Laws.
- (vi) Any misrepresentation under this Section or any violation of the Anti-Terrorism Laws by Developer or Developer's owners, agents, bankers, employees and affiliates shall constitute grounds for immediate termination of this Agreement and any other agreement Developer has entered with Franchisor or an affiliate of Franchisor, in accordance with Section 12.2(xiii) above.
Source: Item 23 — RECEIPT (FDD pages 62–269)
What This Means (2025 FDD)
According to Cinnaholic's 2025 Franchise Disclosure Document, franchisees (referred to as "Developer") and their owners must make several certifications related to compliance with Anti-Terrorism Laws. These certifications are designed to ensure that neither the franchisee nor their assets are in violation of or subject to any restrictions under Anti-Terrorism Laws. Specifically, the franchisee and their owners must certify, represent, and warrant 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 these laws. They also certify that they, their employees, agents, bankers, affiliates, or anyone associated with them are not listed in the Annex to Executive Order 13224.
Furthermore, the franchisee must certify that they have no knowledge or information that, if generally known, would result in the franchisee, their owners, employees, agents, bankers, affiliates, or anyone associated with them being listed in the Annex to Executive Order 13224. It is the franchisee's sole responsibility to understand and take the necessary actions to comply with all Anti-Terrorism Laws.
The Anti-Terrorism Laws, as defined in the FDD, 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 relating to terrorist acts and/or acts of war.
Any misrepresentation or violation of the Anti-Terrorism Laws by the franchisee or their owners, agents, bankers, employees, and affiliates constitutes grounds for immediate termination of the Franchise Agreement and any other agreements with Cinnaholic. This underscores the importance of strict compliance with these laws and the potential consequences of non-compliance.