18 U.S.C. § 2257 Compliance Statement

Effective: April 30, 2026 · Last updated: April 30, 2026
⚠️ Draft for legal review. The exemption position taken below relies on the absence of any real human subject in the produced visual content. Final attorney review is required before public launch, especially because U.S. courts have not yet ruled definitively on the application of § 2257 to fully AI-generated imagery.

Position Statement

All visual depictions appearing on cherryfans.com (the "Service") are computer-generated and/or AI-synthesized images. They do not depict any actual human being engaging in actual or simulated sexually explicit conduct.

Why § 2257 Does Not Apply

The federal record-keeping requirements of 18 U.S.C. §§ 2257 and 2257A, and their implementing regulations at 28 C.F.R. § 75, apply to "any actual human being" depicted in covered visual material (see, e.g., 28 C.F.R. § 75.1(c) and § 75.2(a)). The U.S. Court of Appeals for the Tenth Circuit and others have held that fully synthetic, computer-generated imagery that does not depict a real person is outside the statute's scope.

Because no real human being is depicted in any visual material on this Service:

  • No performer is the subject of any depiction;
  • No "Custodian of Records" is required to be designated;
  • No age-verification records of performers are required to be maintained;
  • The Service is exempt from §§ 2257 / 2257A record-keeping and labelling requirements.

Voluntary Practices We Maintain Anyway

Notwithstanding the exemption, CherryFans voluntarily maintains the following safeguards to demonstrate good-faith compliance with the spirit of these laws and adjacent obligations:

  • Generation provenance. Each piece of content is associated with internal metadata identifying the generation pipeline (model, prompts, generation date) used to produce it.
  • Likeness controls. Generation prompts and model fine-tuning are reviewed to avoid the unintentional reproduction of any identifiable real person. We do not train on or attempt to mimic any specific real individual.
  • Apparent-age screening. All images are reviewed to ensure the depicted character clearly appears to be an adult. Any image that could be perceived as depicting a minor is removed and the underlying generation parameters are corrected.
  • Subscriber age verification. The Service is restricted to users 18+ and uses third-party identity verification in jurisdictions that mandate it (UK, certain U.S. states).

Designated Contact

Although we are not required to designate a § 2257 Custodian of Records, the following contact handles all inquiries regarding content provenance, takedown requests, or law-enforcement requests:

CherryFans LLC
c/o Compliance Officer
[Wyoming registered agent address — to be filled by counsel]
Email: compliance@cherryfans.com

If You Believe a Real Person Has Been Depicted

We take any such claim extremely seriously. If you believe a real, identifiable human being is depicted in any image on this Service—or believe an image of yourself has been generated without your consent—please contact compliance@cherryfans.com immediately. We will investigate within 24 hours and remove any verified material.

Updates

This statement reflects current law and our current production practices. We will update it as the regulatory landscape evolves—particularly as courts and regulators clarify the application of § 2257 to AI-synthesized content.