Is a Clean Your Dirty Face franchisee allowed to enter into prohibited transactions?
Clean_Your_Dirty_Face Franchise · 2025 FDDAnswer from 2025 FDD Document
You must secure and maintain all required licenses, permits and certificates relating to your Business and must at all times operate your Business in full compliance with all applicable laws, ordinances and regulations. You agree to comply and assist us in our compliance efforts with any and all laws and regulations, including those relating to truth in lending, beauty and spa businesses licensing of estheticians, safety and sanitation, truth in advertising, occupational hazards, health and anti-discrimination laws, and anti-terrorist activities or the conduct of transactions involving certain foreign parties, including, without limitation, the U.S. Patriot Act, Executive Order 13224, the U.S. Foreign Corrupt Practices Act, the Bank Secrecy Act, the International Money Laundering Abatement and Anti-terrorism Financing Act, the Export Administration Act, the Arms Export Control Act, the International Economic Emergency Powers Act, and related U.S. Treasury and/or other regulations). In connection with such compliance efforts, you agree not to enter into any prohibited transactions and to properly perform any currency reporting and other activities relating to your Business as may be required by us or by law. You confirm that you, your owners, employees, agents, and representatives are not presently listed (nor has any such individual previously been listed) on the U.S. Treasury Department's List of Specially Designated Nationals, the Annex to Executive Order 13224 (the Annex is currently available at http://www.treasury.gov), or in any other governmental list which prohibits us or you from dealing with such individuals, and agree not to hire any person so listed or have any dealing with a person so listed. You are solely responsible for ascertaining what actions must be taken by you to comply with all such laws, orders and/or regulations, and specifically acknowledge and agree that your indemnification responsibilities (as provided in Section 16.D) apply to your obligations under this Section.
Source: Item 22 — CONTRACTS (FDD page 54)
What This Means (2025 FDD)
According to Clean Your Dirty Face's 2025 Franchise Disclosure Document, franchisees are explicitly prohibited from entering into any transactions that violate applicable laws and regulations. The FDD states that franchisees must comply with all laws and assist Clean Your Dirty Face in complying with laws and regulations related to various issues, including truth in lending, beauty and spa business licensing, safety and sanitation, advertising, health, anti-discrimination, anti-terrorist activities, and transactions involving certain foreign parties.
Specifically, the Franchise Agreement requires Clean Your Dirty Face franchisees to adhere to several U.S. laws, such as the Patriot Act, Executive Order 13224, the Foreign Corrupt Practices Act, the Bank Secrecy Act, the International Money Laundering Abatement and Anti-terrorism Financing Act, the Export Administration Act, the Arms Export Control Act, and the International Economic Emergency Powers Act, along with related U.S. Treasury regulations. Franchisees must also ensure that they, their owners, employees, agents, and representatives are not listed on the U.S. Treasury Department's List of Specially Designated Nationals or any other governmental list that prohibits Clean Your Dirty Face or the franchisee from dealing with them.
The Clean Your Dirty Face franchisee is responsible for understanding and adhering to all applicable laws and regulations. The franchisee also agrees to indemnify Clean Your Dirty Face for any failures to comply with these laws. This means that a Clean Your Dirty Face franchisee must maintain high standards of honesty, integrity, fair dealing, and ethical conduct in all business dealings and avoid any practices that could harm the Clean Your Dirty Face brand or its goodwill.