Under the Even Hotels agreement, what specific actions are prohibited regarding transactions or services that would violate United States economic and trade sanctions?
Even_Hotels Franchise · 2025 FDDAnswer from 2025 FDD Document
(b) acting on behalf of any government of any nation subject to the trade sanctions or embargoes imposed by any of the Sanctioning Bodies;
(c) identified by any of the Sanctioning Bodies as a Prohibited Person; and
(d) in violation of any applicable law relating to anti-money laundering, anti-terrorism, antibribery, trade sanctions or embargoes, narcotics, illegal immigration or human tracking, including without limitation, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, the US Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (US Patriot Act) and related regulations and executive orders related to the foregoing laws (the "Relevant Laws").
(2) Licensee further warrants and represents and covenants that:
(a) Licensee, any Guarantor and any Person having a direct or indirect ownership in Licensee will comply with the Relevant Laws; and
(b) all individuals authorized to represent Licensee in carrying out its obligations under this License are eligible under applicable United States immigration laws to travel to the United States for training or any other purpose in carrying out Licensee's obligations under this License.
(3) For the purposes of this paragraph 13.N., "Person" means any individual, corporation, partnership, joint venture, limited liability company, estate, trust, unincorporated association, any national, provincial, state, county or municipal government or any bureau, office, department or agency thereof and any fiduciary acting in an agency capacity on behalf of any of the foregoing. "Prohibited Person" means any person identified by Her Majesty's Treasury of the United Kingdom ("UK"), by the Office of Foreign Assets Control of the Department of the Treasury of the United States ("US") as a "specially designated national" or otherwise subject to sanction by the European Union ("EU") and/or the United Nations ("UN"), (collectively, "Sanctioning Bodies"), or any other Person with whom IHG, or any of its Affiliates, is otherwise prohibited from transacting business.
Source: Item 23 — RECEIPTS (FDD pages 99–438)
What This Means (2025 FDD)
According to Even Hotels' 2025 Franchise Disclosure Document, franchisees are prohibited from certain actions related to economic and trade sanctions. Specifically, the Even Hotels franchisee cannot act on behalf of any government of any nation subject to trade sanctions or embargoes imposed by sanctioning bodies.
Additionally, the franchisee is prohibited from engaging with individuals or entities identified by sanctioning bodies as a "Prohibited Person." This includes any person identified by Her Majesty's Treasury of the United Kingdom, the Office of Foreign Assets Control of the Department of the Treasury of the United States as a "specially designated national," or otherwise subject to sanction by the European Union and/or the United Nations. The franchisee must also avoid any transaction or service that violates applicable laws related to anti-money laundering, anti-terrorism, anti-bribery, trade sanctions or embargoes, narcotics, illegal immigration, or human tracking, including compliance with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act, and the US Patriot Act.
The Even Hotels franchisee also warrants that they, any guarantor, and any person with ownership in the franchise will comply with all relevant laws. Furthermore, all individuals authorized to represent the franchisee must be eligible under United States immigration laws to travel to the United States for training or any other purpose related to fulfilling the franchisee's obligations under the license. These stipulations ensure that Even Hotels franchisees adhere to international laws and regulations, protecting the brand from legal and reputational risks associated with non-compliance.