18 U.S.C. 2257 Compliance Statement

1. Statement of Compliance

OpenFans is committed to full compliance with the record-keeping requirements of 18 U.S.C. § 2257 and 18 U.S.C. § 2257A, as well as the regulations promulgated thereunder by the Attorney General (28 C.F.R. Part 75). These federal laws require producers of actual sexually explicit content to maintain records demonstrating that all performers depicted in such content are at least 18 years of age at the time of production.

2. Creator Identity Verification

OpenFans requires all Creators to complete a mandatory identity verification process before they are permitted to upload or publish any content on the Platform. This verification process includes:

• Submission of a valid, government-issued photo identification document (passport, driver's license, or national identity card).
• A live selfie or video verification to confirm that the person matches the identification document provided.
• Verification that the Creator is at least 18 years of age.
• Cross-referencing identity information against available databases to detect fraudulent documents.

No Creator account is activated for content publishing until identity verification has been successfully completed and approved.

3. Primary and Secondary Producers

Content on OpenFans is uploaded by individual Creators who act as the primary producers of their content. As primary producers, Creators are responsible for:

• Maintaining age verification records for all individuals depicted in their sexually explicit content.
• Ensuring that all performers are at least 18 years of age at the time of content production.
• Retaining copies of valid identification documents for all performers and maintaining these records in accordance with 28 C.F.R. Part 75.
• Making records available for inspection as required by law.

OpenFans, where applicable, acts as a secondary producer by hosting and distributing content produced by Creators. In this capacity, OpenFans maintains records of all Creator identity verifications and cooperates with any lawful request for inspection of such records.

4. User-Generated Content Exemption

Certain content on OpenFans may qualify for the exemption under 28 C.F.R. § 75.1(c)(4) for content that is produced by users of an interactive computer service. To the extent that content on the Platform qualifies as user-generated content under this exemption, the record-keeping requirements of 18 U.S.C. § 2257 may not apply to OpenFans as the hosting platform.

Regardless of any applicable exemptions, OpenFans maintains its commitment to verifying the identity and age of all Creators and takes proactive measures to prevent the upload of any content depicting minors.

5. Record Retention

In accordance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75, OpenFans maintains records for every Creator who publishes content on the Platform. These records include:

• The legal name and date of birth of the Creator, as verified against a government-issued photo identification document.
• A copy of the identification document submitted during the verification process.
• A selfie or live image captured at the time of verification to confirm the identity of the Creator matches their identification document.
• The date of verification and the identity of the reviewing compliance officer.

All records are created automatically upon successful identity verification and are retained for the duration required by law. Records are stored securely and are accessible only to authorized compliance personnel.

6. Records Custodian

The custodian of records required to be maintained pursuant to 18 U.S.C. § 2257 and 28 C.F.R. Part 75 is:

Records are maintained at the principal office of the records custodian and are available for inspection during normal business hours in accordance with applicable law.

7. Creator Obligations

By using OpenFans to publish content, all Creators acknowledge and agree to the following obligations:

• They will not upload any content depicting any individual under the age of 18.
• They will obtain and maintain valid identification records for all individuals who appear in their sexually explicit content.
• They will retain such records for the period required by law and make them available for lawful inspection.
• They will comply with all applicable federal, state, and local laws regarding the production and distribution of adult content.
• Violation of these obligations may result in immediate account termination, content removal, and referral to law enforcement authorities.

8. Contact

For questions regarding this 2257 compliance statement or records inspection requests, please contact the records custodian at legal@openfans.online.