18 U.S.C. §2257 Compliance Notice

01Statement of non-production

Agency of Creators is a creator-management services company. With respect to any visual depictions hosted on third-party platforms by clients we represent, Agency of Creators is not a "producer" as that term is defined in 18 U.S.C. §2257 and 28 C.F.R. §75.1(c).

All content depicted on accounts under our management is produced by, owned by, and the responsibility of the individual content creator. Agency of Creators does not create, manage the creation of, digitize, or assemble visual depictions of actual sexually explicit conduct.

02Age verification at intake

Although we are not a producer subject to §2257 record-keeping requirements, our internal policy mandates age verification of every individual we represent before any engagement begins. No exception is made; no waiver is offered.

1. Government-issued photo identification is reviewed in person or via verified video call.
2. The identification is matched to the individual on the call by visual confirmation and date-of-birth check.
3. A copy of the identification is retained in encrypted storage with access limited to compliance personnel.
4. An attestation of age and consent is countersigned by the client at the start of the Service Agreement.

03Records held by third parties

Each platform on which our clients distribute content operates its own §2257-compliant record-keeping system. Those records are maintained by the platforms, not by us, and any §2257 inquiry concerning specific visual depictions should be directed to the platform on which the depiction appears.

Where applicable, the §2257 custodian designations for major platforms our clients commonly use are publicly disclosed by those platforms in their respective compliance notices.

04Exemption reliance

To the extent any activity we engage in could be construed as falling within the definition of a producer, we rely on the secondary-producer exemption set forth in 28 C.F.R. §75.7, including but not limited to:

• Our reliance on the original producer's age-verification records, supplemented by our own at-intake verification described above.
• Our limitation of activities to scheduling, communication, promotion, and accounting functions, none of which involve creation, digitization, or assembly of visual depictions.
• The exemption for activities that are mere transmission or routing, where applicable.

05Internal compliance standards

Beyond what §2257 itself requires, we maintain the following internal standards as a matter of policy.

• No content is scheduled, distributed, or promoted on behalf of any client whose age has not been verified through the process described in §02.
• All staff with any client-facing role complete annual training on age-verification, consent, and applicable federal record-keeping law.
• A designated compliance officer reviews intake records monthly and audits the entire client roster annually.
• Any credible report of underage content is treated as cause for immediate termination of the engagement and referral to NCMEC where applicable.

06Custodian of internal records

For inquiries concerning Agency of Creators' internal age-verification records (as distinct from §2257 records, which are held by platforms), the designated custodian is identified below. Inquiries from law enforcement must be accompanied by valid, jurisdictionally appropriate legal process.