18 U.S.C. § 2257 — Record-Keeping Requirements & Compliance Statement

BRDXVG, operating the digital platform at brdxvg.com ("Operator"), hereby declares that it maintains full compliance with the record-keeping requirements imposed by 18 U.S.C. § 2257 and the implementing regulations promulgated thereunder at 28 C.F.R. Part 75.

All performers, talent, models, and individuals depicted in any visual depiction of sexually explicit conduct, as defined at 18 U.S.C. § 2256(2), that appears on, is distributed through, or is otherwise made accessible via this Platform, were verifiably eighteen (18) years of age or older at the time of production of such depiction.

18 U.S.C. § 2257, enacted as part of the Child Protection and Obscenity Enforcement Act, imposes affirmative obligations on producers of sexually explicit content to obtain, maintain, and make available for inspection records establishing that all depicted performers were adults at the time of production.

The statute operates in conjunction with 18 U.S.C. § 2257A, which extends analogous obligations to producers of simulated sexually explicit conduct, and with 28 C.F.R. Part 75, which specifies in granular detail the format, content, location, and availability of required records.

Failure to comply with the record-keeping mandates of § 2257 constitutes a federal criminal offence under 18 U.S.C. § 2257(i), potentially resulting in imprisonment of up to five (5) years for a first offence and up to ten (10) years for subsequent offences.

The regulatory framework distinguishes between two categories of producers, each carrying distinct compliance obligations:

• Primary Producer: Any person who produces, finances, or directs a visual depiction of actual sexually explicit conduct, as defined under 18 U.S.C. § 2257(h)(2)(A). Primary producers bear the full record-keeping burden, including acquisition of age-verification documentation prior to or contemporaneously with production.
• Secondary Producer: Any person who produces, assembles, manufactures, publishes, duplicates, reproduces, or reissues a book, magazine, periodical, film, videotape, digital image, digitally- or computer-manipulated image, picture, or other matter, or who inserts on a computer site or service a digital image, that contains a visual depiction of an actual sexually explicit act and who is not the primary producer of that visual depiction, pursuant to 18 U.S.C. § 2257(h)(2)(B).

BRDXVG operates in its capacity as a secondary producer with respect to third-party content and as a primary producer with respect to content originated directly by the Operator. The applicable compliance obligations are fulfilled in each context as described in §§ 04–07 of this Statement.

Pursuant to 28 C.F.R. § 75.2, the Operator maintains the following records for all content for which it acts as a primary producer:

1. A copy of an identification document, as defined in 28 C.F.R. § 75.1(c), for each performer depicted.
2. The legal name and date of birth of each performer as evidenced by such identification document.
3. All names — including any maiden names, aliases, nicknames, pseudonyms, or stage names — under which each performer is known.
4. A cross-reference index to the specific content in which each performer appears.
5. For each visual depiction: the URL, title, or other identifier sufficient to unambiguously associate the record with the content.

Records are indexed in conformity with 28 C.F.R. § 75.2(a)(1) using a unique content identifier system that enables prompt retrieval upon lawful inspection request.

The Operator has implemented a multi-stage age verification protocol applicable to all production activities conducted under its direct supervision:

1. Pre-production screening: All prospective performers must submit valid identification documentation for review no less than forty-eight (48) hours prior to any scheduled production activity.
2. On-set verification: At the commencement of each production session, a designated compliance officer verifies the physical identity of each performer against the pre-submitted documentation.
3. Document imaging: High-resolution copies of all identification documents are made, authenticated, and filed in the centralised record-keeping system within twenty-four (24) hours of production.
4. Record cross-referencing: Performer records are linked to the specific content identifiers generated for each production session prior to any distribution, publication, or public accessibility.
5. Periodic audits: The Compliance Division conducts quarterly internal audits of all § 2257 records to identify and remediate any gaps or deficiencies.

With respect to content produced by third parties and made accessible through the Platform, the Operator operates in its capacity as a secondary producer. The Operator requires, as a contractual precondition of content submission and distribution, that all primary producers provide written attestation of their compliance with 18 U.S.C. § 2257 and 28 C.F.R. Part 75 and that they maintain all requisite records in accordance with applicable law.

Pursuant to 28 C.F.R. § 75.8(b), the location of records maintained by third-party primary producers may be obtained by contacting the Operator's Records Custodian at the address specified in § 09 of this Statement.

In accordance with 28 C.F.R. § 75.5, all records required to be maintained under 18 U.S.C. § 2257 are available for inspection by the Attorney General of the United States, or any duly authorised representative thereof, during regular business hours at the address of the Records Custodian identified in § 09 below, subject to reasonable advance notice as prescribed by regulation.

Inspection requests must be submitted in writing to the Records Custodian and must identify the specific categories of records sought. The Operator will cooperate fully with all lawfully authorised inspections and will not impede, obstruct, or delay any regulatory access to which the requesting authority is legally entitled.

The Operator has designated the following individual or functional unit as the Custodian of Records for the purposes of 18 U.S.C. § 2257 and 28 C.F.R. Part 75:

Any person who has a reasonable basis to believe that content accessible via brdxvg.com depicts a minor, or that any provision of 18 U.S.C. § 2257 has been violated in connection with content on this Platform, is strongly encouraged to report such concerns immediately to the Records Custodian at compliance@brdxvg.com.

Reports may also be made to the National Center for Missing & Exploited Children (NCMEC) via its CyberTipline at missingkids.org/cybertipline , or to the Federal Bureau of Investigation at fbi.gov .

This Compliance Statement is reviewed by the Compliance Division on a semi-annual basis and is updated as necessary to reflect changes in applicable statutory or regulatory requirements, operational practices, or the Operator's legal structure. The document reference number (BRDXVG-COMP-2257-02) and the "Last Revision" date in the metadata panel are updated upon each revision.

Prior versions of this Statement are archived and may be requested from the Records Custodian identified in § 09. All archived versions are retained in accordance with applicable record-keeping obligations.