18 U.S.C. § 2257 Compliance Statement
Effective date: 2026-05-11
1. Statement
All visual depictions of actual sexually-explicit conduct appearing on or accessible through Auravia are exempt from the provisions of 18 U.S.C. § 2257 and 28 C.F.R. § 75, or, where not exempt, are in compliance with those provisions. The producers of the content uploaded to the Platform have represented to Auravia Ltd. that each performer depicted was, at the time of production, an adult of at least 18 years of age, and that records of age have been created and are maintained in accordance with 18 U.S.C. § 2257.
2. Custodian of Records
Auravia hosts content produced by independent Creators and Agencies. Under 28 C.F.R. § 75, the records for each depiction are maintained by the producer of that content — i.e. the Creator or Agency that produced it. Accordingly, there is no single custodian for all content on the Platform. The designated Custodian of Records for each creator's content is published on that creator's own storefront, in the § 2257 statement linked from the foot of every storefront page (at /m/<creator>/2257).
For content where Auravia Ltd. is itself the producer, or where an Agency has elected Auravia Ltd.'s managed records-keeping programme, the Custodian of Records is:
- Custodian: Office of the Custodian of Records, Auravia Ltd.
- Address: Anthypolochagou Georgiou M.Savva, 26, SHOP 1-2, Geroskipou, 8201, Paphos, Cyprus
- Business hours: Monday–Friday, 09:00–17:00 (local time), excluding public holidays
- Contact: legal@fanclave.io
Records are available for inspection by authorised officials of the U.S. Department of Justice during the stated business hours, in accordance with 28 C.F.R. § 75.5. For content not maintained by Auravia Ltd., inspection requests are directed to the producer's designated custodian as published on the relevant creator's storefront statement.
3. Records maintained
For each performer depicted in covered content, the records maintained include:
- the performer's legal name and any stage names, pseudonyms, professional names, or aliases used in the content;
- the performer's date of birth;
- a copy of a picture identification card containing the performer's name, date of birth, and photograph, issued by a government agency or governmental jurisdiction;
- where applicable, a second picture identification document;
- a signed model release authorising production and distribution.
Records are cross-indexed in a system that permits retrieval by performer legal name, by stage name or alias, and by URL or content identifier of each depiction in which the performer appears.
4. Producer status
Auravia Ltd. operates Auravia as a platform that hosts content uploaded by independent Creators and Agencies. With respect to most content on the Platform, Auravia Ltd. is a "secondary producer" within the meaning of 28 C.F.R. § 75.1(c)(2) and not the primary producer who creates the depiction. Creators and Agencies contractually represent that they are the primary producers and that the records required of primary producers under 18 U.S.C. § 2257 are maintained at the address the Creator/Agency designates, which may be different from the Custodian above.
5. Exempt depictions
Where any content on the Platform is exempt from 18 U.S.C. § 2257 — for example, because it was produced before the relevant effective dates, or because it consists of depictions of conduct that does not fall within the statutory definition of "actual sexually-explicit conduct" — that content remains hosted in reliance on the producer's representation as to its exempt status.
6. Compliance contact
Questions about this statement or about records held by Auravia Ltd.: legal@fanclave.io. For takedown of specific content, please use our DMCA / Takedown procedure.
Reference: 18 U.S.C. § 2257; 18 U.S.C. § 2257A; 28 C.F.R. § 75.