Does the Focalpoint Coaching franchise agreement address compliance with anti-terrorism and other laws?
Focalpoint_Coaching Franchise · 2025 FDDAnswer from 2025 FDD Document
19. COMPLIANCE WITH ANTI-TERRORISM AND OTHER LAWS.
Franchisee and Franchisee's owners agree to comply, and to assist Franchisor to the fullest extent possible in Franchisor's efforts to comply, with all applicable legislation, laws, regulations, rules, ordinances, administrative orders, decrees and policies of any court, arbiter, government, governmental agency, department, or similar organization that are in effect from time to time pertaining to: (a) the various anti-terrorism, economic sanctions, and anti-money laundering and narco-trafficking laws, regulations, orders, decrees and guidelines of the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC"), (b) the USA PATRIOT Act (Title III of Pub. L. 107-56, signed into law October 26, 2001), as amended, (c) the provisions of United States Executive Order 13224, (d) the U.S. Prevention of Corruption Act 1988, (e) the U. S. Foreign Corrupt Practices Act, 15 U.S.C. Section 78dd-2, (e) relevant multilateral measures such as the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions and the UN Convention Against Corruption, (f) bribery and anti-corruption laws, (g) the laws against money laundering, and (h) the laws against facilitating or supporting persons who conspire to commit these and other crimes against any person or government. Franchisee immediately shall notify Franchisor in writing if a potential violation of any of the foregoing legislation, laws, regulations, rules, ordinances, administrative orders, decrees and/or policies has occurred or is suspected to have occurred. Franchisee immediately shall provide Franchisor with copies of any communication to or from any such agency, government, or commission that relates to or affects this Agreement, the Franchised Business, or the Marks. Any failure to comply with this Section by Franchisee or Franchisee's owners, or any blocking of Franchisee's or Franchisee's owners' assets under any of such laws, legislation, regulations, orders, decrees and/or policies shall constitute good cause for immediate termination of this Agreement, as provided in Section 14.B(18) above.
Source: Item 22 — Contracts (FDD pages 56–57)
What This Means (2025 FDD)
Yes, according to the 2025 Focalpoint Coaching Franchise Disclosure Document, the franchise agreement includes a section addressing compliance with anti-terrorism and other laws.
Specifically, Focalpoint Coaching requires franchisees and their owners to comply with a comprehensive list of laws and regulations related to anti-terrorism, economic sanctions, anti-money laundering, and anti-corruption. This includes adherence to guidelines from the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), the USA PATRIOT Act, United States Executive Order 13224, the U.S. Prevention of Corruption Act 1988, the U.S. Foreign Corrupt Practices Act, OECD Convention on Combating Bribery of Foreign Public Officials, UN Convention Against Corruption, and various bribery, anti-corruption, and money laundering laws.
The Focalpoint Coaching franchise agreement also mandates that franchisees must immediately inform the franchisor in writing if any potential violation of these laws or regulations has occurred or is suspected. Franchisees are also required to provide Focalpoint Coaching with copies of any communications to or from any government agency related to the agreement, the franchised business, or the brand's trademarks.
Failure to comply with these provisions or the blocking of a franchisee's assets under any of these laws constitutes grounds for immediate termination of the Focalpoint Coaching franchise agreement. This clause places a significant responsibility on the franchisee to ensure full compliance with all specified legal requirements, with potentially severe consequences for any breaches.