18 U.S.C. §§ 2257 & 2257A Compliance Statement
Last updated: 2026-08-02 · ASM Media Group LLC
1. Scope and Legal Basis
This statement is made pursuant to 18 U.S.C. § 2257 and § 2257A and the implementing regulations at 28 C.F.R. Part 75. It applies to all visual depictions of actual or simulated sexually explicit conduct that ASM Media Group LLC ("the Operator") produces, generates, hosts, or otherwise makes available through letshoot.ai and its associated creator portal (collectively, "the Platform").
For every such depiction, the Operator creates and maintains the age, identity, and consent records required by law, and it publishes this statement in accordance with 28 C.F.R. § 75.6 and applicable payment-card-network rules. This statement is an internal compliance framework and does not constitute legal advice to any user.
2. All Persons Depicted Are Adults; Only the Creator's Own Verified Likeness
Every individual who appears in, or whose likeness is used to generate, any depiction available through the Platform is a real, identified adult who was at least eighteen (18) years of age at the time the source likeness material was produced and at the time any depiction was generated. The Platform contains no depiction of any person under eighteen (18).
The Platform trains and uses a per-creator AI likeness model (a "digital clone") solely from photographs and videos of the consenting creator's own face and body. A creator may only clone and generate depictions of their own verified likeness. Uploading, cloning, or generating the likeness of any other person — whether real or fictitious, and whether or not that person consents — is strictly prohibited and constitutes grounds for immediate termination.
3. Producer Status
With respect to the depictions created, generated, and made available through the Platform, the Operator acts as a "producer" — including, as applicable, both a primary and a secondary producer — within the meaning of 18 U.S.C. §§ 2257 and 2257A and 28 C.F.R. Part 75. Accordingly, the Operator undertakes the age-verification, consent, and recordkeeping obligations of a producer for all such depictions, including those depicting simulated sexually explicit conduct within the scope of § 2257A.
4. Treatment of AI-Generated Depictions; No Fully-Synthetic Exemption Claimed
The AI-generated images and videos offered through the Platform are not depictions of fictitious or wholly computer-generated persons. Each depiction is generated from, and portrays, the likeness of a specific, real, identifiable, consenting adult — the creator whose digital clone produced it.
For this reason, the Operator does not claim, assert, or rely upon any exemption that may be available for images that do not portray an actual human being. As a matter of policy, the Operator voluntarily treats every AI-generated depiction of a verified real adult as subject to the same age-verification and recordkeeping obligations that would apply to an ordinary photographic or video depiction of that same person, and it maintains the corresponding records tied to the real adult whose likeness is depicted.
5. Age, Identity, and Consent Records
Before any likeness model is trained, the Operator verifies each creator's age and identity using at least one valid, unexpired government-issued photographic identification document, together with additional confirmation linking the person presenting the identification to the likeness being cloned (for example, a contemporaneous verification image or liveness check).
The Operator obtains and retains dated, signed consent from each creator that authorizes (i) the capture and use of their source likeness material, (ii) the training of their AI likeness model, and (iii) the ongoing generation of adult depictions from that model. Records are indexed by the creator's legal name and cross-referenced to any stage names, aliases, or URLs under which the resulting depictions are distributed.
For each depiction, the Operator maintains the dates relevant to its production, including the date the source likeness material was produced, the date of age and identity verification, the date consent was given, and the date the depiction was generated. Age, identity, and biometric verification data are collected, stored, and destroyed in accordance with the Operator's Privacy Policy and applicable law.
6. Custodian of Records
The Custodian of Records designated to maintain the records required by 18 U.S.C. §§ 2257 and 2257A for the depictions produced through the Platform is: «[TO BE SET: full legal name and title of the designated Custodian of Records]».
The required records are maintained at the following physical location: «[TO BE SET: physical U.S. street address of the Custodian of Records — a street address, not a P.O. box]».
The records are available for inspection during the following regular business days and hours: «[TO BE SET: inspection days and hours, e.g., Monday–Friday, 9:00 a.m. to 5:00 p.m. local time, by prior appointment]».
7. Records Retention
The Operator retains all records required under 28 C.F.R. Part 75 for the period required by law — no less than seven (7) years from the date the depiction was created, and, should the Operator cease to carry on the business, for a further five (5) years thereafter — after which the records are securely and permanently destroyed. Verification and biometric data associated with these records are retained and destroyed in accordance with the Operator's Privacy Policy and applicable data-protection law.
8. Zero Tolerance for Minors and CSAM
The Operator has zero tolerance for any depiction that involves, or that appears to involve, a minor. No person under eighteen (18) years of age may be verified, cloned, or depicted, and no depiction of any minor — real or simulated — will ever be produced, generated, hosted, or made available.
Any attempt to upload, clone, request, or generate content involving a minor results in immediate account termination, preservation of the relevant records and evidence, and reporting to the National Center for Missing & Exploited Children (NCMEC) and to the appropriate law-enforcement authorities as required by law.
9. Questions and Contact
Questions regarding this statement or the Operator's compliance with 18 U.S.C. §§ 2257 and 2257A may be directed to ASM Media Group LLC at soporte@letshoot.ai. This statement may be updated from time to time; the version published at letshoot.ai/usc2257 is the current and controlling version.