Purpose and scope of this Compliance Policy

1.1 This 2257 / Explicit Creator Content Compliance Policy applies to Creators and other Members who upload, distribute, sell or otherwise make available through SULTRAFIED Content depicting real people in sexually explicit or other qualifying adult Content.

1.2 It establishes SULTRAFIED’s contractual standards for performer age, identity, record keeping, consent, Content traceability and related compliance.

1.3 This Policy also explains how United States federal record-keeping requirements under 18 U.S.C. §§ 2257 and 2257A may affect particular Content, Creators, producers, publishers or other persons.

1.4 This Policy operates alongside the SULTRAFIED Creator Terms, Member Content Licence, Age Assurance requirements, Online Safety Policy, Privacy Policy and other applicable legal and Platform rules.

1.5 SULTRAFIED may impose a Platform compliance standard stricter than the minimum obligation that a particular Creator believes applies under local law.

United States record-keeping framework

2.1 United States federal law establishes record-keeping requirements for persons to whom 18 U.S.C. § 2257 applies in connection with covered visual depictions of actual sexually explicit conduct.

2.2 18 U.S.C. § 2257A contains related requirements concerning covered visual depictions of simulated sexually explicit conduct.

2.3 The statutory and regulatory framework may require, among other things:

2.4 Whether a particular person, organisation, website or Content item falls within those requirements depends on the applicable statute, regulations, facts and legal classification.

SULTRAFIED does not make an unsupported producer or exemption declaration

3.1 The term “produces” under the applicable United States framework can extend beyond the person who originally photographs or films a performer.

3.2 Depending on the facts, statutory concepts may also concern certain activities involving publishing, inserting or managing sexually explicit Content on a computer site or service.

3.3 The law also contains exclusions and exemptions that may apply to particular activities or material.

3.4 SULTRAFIED therefore does not state in this Policy that it is categorically:

3.5 SULTRAFIED’s precise obligations will be determined according to its actual activities and applicable law.

3.6 Nothing in a Creator’s own classification of their Content binds SULTRAFIED or prevents SULTRAFIED from requiring additional compliance evidence.

Every performer must have been 18 or older at creation

4.1 Every actual human being depicted in sexual or explicit Creator Content must have been at least 18 years old when the relevant Content was created.

4.2 It is not sufficient that the person is 18 when the Content is uploaded.

4.3 If Content was created when a depicted person was under 18, that Content must never be uploaded to SULTRAFIED merely because the person has since reached adulthood.

4.4 A Creator must not rely solely on:

4.5 SULTRAFIED may require documentary and other verification evidence appropriate to the applicable Content and legal requirements.

Identity documents and performer information

5.1 Where a Creator or other person is subject to applicable § 2257 or § 2257A record-keeping requirements, that person must maintain the performer identity records required by law.

5.2 Required records may include examination and recording of information from an appropriate identification document showing the performer’s identity and date of birth.

5.3 Applicable records may also require information about other names used by the performer, including relevant:

5.4 Records must be genuine, accurate and capable of being associated with the correct performer.

5.5 A Creator must never fabricate, alter or substitute another person’s identity document to satisfy SULTRAFIED or legal requirements.

Records must be traceable to the relevant Content

6.1 Merely possessing an unidentified collection of identity documents is not an adequate SULTRAFIED compliance process.

6.2 The Creator should be able to identify which verified performers appear in the relevant Content.

6.3 Depending on applicable requirements, useful traceability information may include:

6.4 SULTRAFIED may use its own Content identifiers, upload records and Creator Account records to assist compliance and investigation.

Content potentially within 18 U.S.C. § 2257

7.1 Section 2257 concerns covered visual depictions of actual sexually explicit conduct as defined under applicable United States federal law.

7.2 Creators must not assume that Content falls outside the law merely because:

7.3 Whether the statute applies requires assessment of the actual Content, production, distribution, jurisdictional facts and legal definitions.

7.4 Where a Creator is unsure whether U.S. record-keeping requirements apply, the Creator should obtain appropriate independent legal advice before distributing the Content.

Content potentially within 18 U.S.C. § 2257A

8.1 Section 2257A contains record-keeping provisions for certain covered visual depictions of simulated sexually explicit conduct involving actual human beings.

8.2 Creators must not automatically assume that a simulated depiction is outside all U.S. record-keeping requirements.

8.3 Statutory exemptions may exist for particular material, but those exemptions are subject to specific legal conditions.

8.4 A Creator relying on an exemption remains responsible for determining that the exemption genuinely applies.

8.5 SULTRAFIED may nevertheless require adult identity and performer-consent evidence as a Platform condition even if a Creator considers a particular statutory record-keeping exemption applicable.

Creator certification before explicit Content is accepted

9.1 SULTRAFIED may require a Creator to provide an affirmative certification when uploading or monetising applicable explicit Content.

9.2 The Creator may be required to certify that:

9.3 The certification should be recorded against the Creator Account and applicable Content or upload transaction.

9.4 SULTRAFIED may retain the version of the certification wording accepted by the Creator.

Age verification and consent are separate requirements

10.1 Evidence that a performer is an adult does not itself establish that the performer consented to:

10.2 Creators must separately ensure that they have sufficient permission and legal authority for the intended upload and distribution.

10.3 Where appropriate, SULTRAFIED may require separate performer release or consent evidence.

10.4 An identification document must not be treated as a performer release.

Verification applies to everyone depicted

11.1 Creator verification alone is not sufficient where Content depicts additional performers.

11.2 Each real person whose participation requires age, identity, consent or statutory records must be independently accounted for.

11.3 This applies to:

11.4 A Creator must not upload Content depicting an unverified partner merely because the Creator’s own SULTRAFIED Account has been verified.

Licensed, purchased or externally produced Content

12.1 A Creator must not assume that buying or licensing Content eliminates performer-record obligations.

12.2 Before uploading externally produced explicit Content, the Creator must have sufficient information to establish:

12.3 SULTRAFIED may require information identifying the original producer or applicable record custodian.

12.4 Content may be rejected where the compliance chain is incomplete or unreliable.

SULTRAFIED may request supporting records

13.1 SULTRAFIED may require a Creator to provide appropriate evidence relating to performer age, identity, consent and record keeping.

13.2 A request may arise:

13.3 SULTRAFIED may use a specialist verification or compliance provider for this process.

13.4 SULTRAFIED’s review of records does not transfer the Creator’s independent statutory obligations to SULTRAFIED.

13.5 Approval of Content does not amount to a legal opinion that every obligation applicable to the Creator has been satisfied.

Records-location statements where legally required

14.1 United States law may require a person to whom the applicable record-keeping provisions apply to affix a statement identifying where required performer records may be located.

14.2 For applicable website material, statutory rules may extend the statement requirement to pages containing covered Content.

14.3 Where the responsible person is an organisation, legally required information may include the responsible record keeper’s name, title and business address.

14.4 SULTRAFIED will not publish invented or placeholder record-custodian information.

14.5 If SULTRAFIED is legally required to maintain and publish such a statement for particular Content, SULTRAFIED will establish the relevant record custodian and compliant records location before publishing the required details.

Applicable records must be retained for the required period

15.1 Where 28 C.F.R. Part 75 applies, required producer records are subject to regulatory retention rules.

15.2 The current federal regulation generally requires each applicable record to be maintained for seven years from its creation or last amendment or addition.

15.3 Separate retention rules apply where the producer ceases carrying on the relevant business.

15.4 Creators must not delete legally required records merely because:

15.5 SULTRAFIED’s own retention of Creator or verification information is governed separately by its applicable legal obligations and Privacy Policy.

Performer identity documents must be handled securely

16.1 Performer identity and age records contain highly sensitive personal information.

16.2 They must not be placed in a public profile, public Creator gallery or ordinary public Content area.

16.3 Where SULTRAFIED requires documents, it may require submission through an appropriate verification or secure compliance process rather than ordinary public messaging.

16.4 Relevant security considerations may include:

16.5 U.S. record-keeping obligations do not remove applicable UK or other privacy and data-protection responsibilities.

Editing or artificial intelligence does not automatically remove compliance obligations

17.1 Creators must not assume that Content is outside relevant legal requirements merely because it has been edited, digitally manipulated or processed using artificial intelligence.

17.2 Where an actual human being or source performance is depicted, relevant age, identity, consent, intellectual-property and Content rules may continue to apply.

17.3 SULTRAFIED separately prohibits deceptive or non-consensual manipulated intimate Content where it breaches law or Platform rules.

17.4 The legal treatment of fully synthetic material may differ from Content depicting actual human beings and must be assessed according to the applicable law and facts.

No sexual Content involving anyone under 18

18.1 SULTRAFIED prohibits sexual or sexualised Content involving anyone who was under 18 when the Content was created.

18.2 This applies regardless of:

18.3 Where SULTRAFIED has a credible concern that a person depicted may have been under 18, the Content may be immediately restricted while the matter is assessed.

18.4 SULTRAFIED may preserve and report information where required or permitted by applicable law.

Compliance fraud is a serious Platform violation

19.1 Creators must not knowingly provide false, misleading, altered or fabricated:

19.2 A Creator must not complete another performer’s verification by impersonating that person.

19.3 SULTRAFIED may treat deliberate falsification as a serious trust and safeguarding breach.

19.4 Where deliberate falsification is reasonably established, permanent Account termination may follow.

SULTRAFIED may restrict Content pending compliance

20.1 SULTRAFIED may refuse publication, restrict access, suspend sales or remove Content where required compliance evidence is unavailable, incomplete, inconsistent or unreliable.

20.2 Depending on the circumstances, SULTRAFIED may:

20.3 SULTRAFIED may apply immediate precautionary restrictions where there is an age, identity or consent concern.

20.4 Temporary restriction does not by itself constitute a final finding of criminal wrongdoing.

Cooperation with legally authorised authorities

21.1 Persons directly responsible for statutory § 2257 or § 2257A records must satisfy applicable record availability and inspection obligations.

21.2 SULTRAFIED may disclose information in response to a valid legal requirement, court order, regulatory request or law-enforcement process where disclosure is required or permitted by applicable law.

21.3 SULTRAFIED may verify the authority and legal validity of a request before disclosure where appropriate.

21.4 Nothing in this Policy authorises ordinary Members to demand another Creator’s private identity records.

Creators outside the United States

22.1 SULTRAFIED may be used by Creators located in different jurisdictions.

22.2 A Creator’s physical location outside the United States does not entitle the Creator to assume that United States law can never be relevant to Content distributed into or through the United States.

22.3 Creators are responsible for complying with laws that apply to their production and distribution activity.

22.4 SULTRAFIED may require a globally consistent performer-verification standard even where particular local laws differ.

22.5 Nothing in this Policy reduces obligations under UK, EU or other applicable laws concerning age, exploitation, consent, privacy or illegal Content.

Closing SULTRAFIED does not automatically end legal record duties

23.1 A Creator’s deletion of Content or closure of their SULTRAFIED Account does not automatically terminate any independent legal obligation to retain records.

23.2 Creators remain responsible for complying with applicable statutory retention periods after Account closure.

23.3 SULTRAFIED may itself retain restricted information where necessary for:

Creators remain responsible for obligations that apply to them

24.1 SULTRAFIED provides Platform rules and compliance controls but does not take over a Creator’s independent statutory record-keeping duties merely by hosting Content.

24.2 A Creator must determine whether they or another person connected to the production has obligations under applicable law.

24.3 SULTRAFIED may require contractual compliance even where the Creator believes a particular statutory provision does not apply.

24.4 SULTRAFIED reserves the right not to host or monetise Content where its age, consent, ownership, record-keeping or legal status cannot reasonably be established.

24.5 Creator warranties, indemnities and liability are additionally governed by the SULTRAFIED Creator Terms and main Terms & Conditions.

Changes to law or SULTRAFIED compliance procedures

25.1 SULTRAFIED may update this Policy or its Creator verification procedures to reflect changes in:

25.2 Material contractual changes will be communicated where required.

25.3 A Creator may be required to complete updated compliance certification before continuing to use affected functionality.