What representation does the Itan franchisee make regarding anti-terrorism laws?
Itan Franchise · 2025 FDDAnswer from 2025 FDD Document
- **23.3.
Anti-Terrorism Compliance.** 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.
The foregoing representations and warranties are 'continuing' representations and warranties for the duration of the franchise relationship.
Accordingly, you must immediately notify us of the occurrence of an event or development of a circumstance that might render any of the foregoing representations and warranties false, inaccurate or misleading.
Source: Item 23 — RECEIPT (FDD pages 44–190)
What This Means (2025 FDD)
According to Itan's 2025 Franchise Disclosure Document, the franchisee and its owners must jointly and severally represent and warrant their compliance with anti-terrorism laws. Specifically, they must declare that, to the best of their knowledge: no property they own is subject to being "blocked" under any Anti-Terrorism Law; neither they, any owner, nor their funding sources are terrorists or suspected terrorists, or identified on any Terrorist List, including the U.S. Treasury Department's list of "Specially Designated Nationals" or "Blocked Persons"; and they are in compliance with all Anti-Terrorism Laws and other U.S. laws that prohibit corrupt business practices, money laundering, or support for those who commit acts of terror.
This representation is a 'continuing' one for the duration of the franchise relationship, meaning the franchisee's compliance and awareness are ongoing obligations. The franchisee must immediately notify Itan if any event or circumstance arises that could render these representations false, inaccurate, or misleading.
This requirement is fairly standard in franchising, as franchisors need to protect their brand and reputation from any association with illegal activities. By requiring this representation, Itan aims to ensure that its franchisees meet legal and ethical standards related to anti-terrorism and financial integrity. A prospective franchisee should understand the seriousness of this representation and ensure full compliance with all applicable laws and regulations.