Does Cream require franchisees to comply with U.S. anti-money laundering and counter-terrorism financing laws and regulations?
Cream Franchise · 2025 FDDAnswer from 2025 FDD Document
Specially Designated Nationals; (ii) the U.S. Commerce Department's Denied Persons List, Unverified List, Entity
List, or General Orders; (iii) the U.S. State Department's Debarred List or Nonproliferation Sanctions; or (iv) the Annex to U.S. Executive Order 13224.
(2) A person or entity who assists, sponsors, or supports terrorists or acts of terrorism, or is owned or controlled by terrorists or sponsors of terrorism.
You further represent and warrant to us that you and your owners are now, and have been, in compliance with U.S. anti-money laundering and counter-terrorism financing laws and regulations, and that any funds provided by you or your owners to us or our affiliates are and will be legally obtained in compliance with these laws. You agree not to, and to cause all of your owners, employees, agents, representatives, and any other person or entity associated with you not to, during the Term, take any action or refrain from taking any action that would cause such person or entity to become a target of any such laws and regulations.
20. EXECUTION.
This Agreement may be executed in multiple counterparts, each of which shall be deemed to be an original and all of which taken together shall constitute one and the same agreement. This Agreement may be executed by electronic means.
[Signature Page to Follow]
IN WITNESS WHEREOF, the parties have executed and delivered this Agreement on the dates noted below, to be effective as of the Effective Date.
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Source: Item 23 — RECEIPTS (FDD pages 61–192)
What This Means (2025 FDD)
According to Cream's 2025 Franchise Disclosure Document, franchisees must comply with U.S. anti-money laundering and counter-terrorism financing laws and regulations. Cream requires franchisees to represent and warrant that they and their owners are currently in compliance with these laws and regulations. They must also ensure that any funds provided to Cream or its affiliates are legally obtained in compliance with these laws.
Furthermore, Cream franchisees must agree not to take any action that would cause them or anyone associated with them to become a target of these laws and regulations during the term of the franchise agreement. This includes their owners, employees, agents, and representatives. Cream also prohibits franchisees and their associates from being listed on governmental lists related to terrorism or being involved in supporting terrorist activities.
Cream emphasizes that the representations regarding compliance with these laws are an express consideration for granting the franchise. This means that a franchisee's adherence to these regulations is a fundamental condition of the franchise agreement. Failure to comply could result in a breach of contract and potential termination of the franchise agreement. This requirement is in line with standard practices in the franchise industry, where franchisors often include clauses to ensure legal and ethical conduct by their franchisees.