What constitutes a 'blocked' property or interest under Itan's Anti-Terrorism Law representation?
Itan Franchise · 2025 FDDAnswer from 2025 FDD Document
You and the Owners jointly and severally represent and warrant to us that, to the best of your and their knowledge: (a) no property or interest owned by you or any Owner is subject to being "blocked" under any Anti-Terrorism Law; (b) neither you nor any Owner, nor any of their respective funding sources (including any legal or beneficial owner of an Equity Interest in the Business or Franchisee Entity) or related parties is, or has ever been: (i) a terrorist or suspected terrorist within the meaning of the Anti-Terrorism Law; or (ii) identified by name, alias, pseudonym, nickname or address on any Terrorist List, including the list of "Specially Designated Nationals" or "Blocked Persons" maintained by the U.S. Treasury Department's Office of Foreign Assets Control (texts currently available at www.home.treasury.gov); and (c) you and the Owners are in compliance with, and shall continue to comply with, the Anti-Terrorism Law and all other U.S.
Laws currently in effect, or enacted in the future, that prohibit corrupt business practices, money laundering or the aid or support of Persons who conspire to commit acts of terror against any Person or government.
Source: Item 23 — RECEIPT (FDD pages 44–190)
What This Means (2025 FDD)
According to Itan's 2025 Franchise Disclosure Document, when you sign the franchise agreement, you and your owners must represent and warrant that no property or interest owned by you is subject to being "blocked" under any Anti-Terrorism Law. You must also represent that neither you nor any owner, nor any of your funding sources or related parties, is or has ever been a terrorist or suspected terrorist as defined by Anti-Terrorism Law. Additionally, you must not be identified on any Terrorist List, including the list of "Specially Designated Nationals" or "Blocked Persons" maintained by the U.S. Treasury Department's Office of Foreign Assets Control.
In practical terms, this means that before signing the franchise agreement, prospective Itan franchisees and their owners must ensure they are not on any government watch lists related to terrorism or money laundering. They should also verify that their funding sources are legitimate and not associated with any illegal activities. This representation is a serious legal matter, and any misrepresentation could have significant consequences, including termination of the franchise agreement.
Itan requires that franchisees comply with all Anti-Terrorism Laws and other U.S. laws that prohibit corrupt business practices, money laundering, or support of those who conspire to commit acts of terror. This compliance is an ongoing obligation throughout the franchise relationship. Franchisees must immediately notify Itan if any event or circumstance arises that could render these representations false, inaccurate, or misleading. This continuing obligation places a responsibility on the franchisee to remain vigilant and proactive in ensuring compliance with these laws.