Relating to the creation of artificial sexual material harmful to minors.

Contracts

• Terms of Service (ToS): You must amend your user agreements to explicitly prohibit the generation of "artificial sexual material harmful to minors." This is a prerequisite for the Safe Harbor defense.
• Vendor Master Services Agreements (MSAs): If you utilize third-party age verification vendors, you must insert strict indemnity clauses. If the vendor retains PII in violation of the statute, your company is liable for the $10,000 per-instance fine. Ensure the contract assigns this liability to the vendor.
• Cloud/API Licensing: If you provide the AI engine to other businesses, clarify in your contracts that the *client* is the "operator" responsible for the front-end verification or filtering.

Hiring/Training

• Engineering/Dev Ops: Immediate allocation of resources is required to either:
• 1. Integrate "affirmative steps" (keyword blocking, image recognition filters) to prevent sexual generation; or
• 2. Integrate third-party identity verification APIs (e.g., ID.me, Veriff) into the user login flow.
• Customer Support: Staff must be trained to handle user complaints regarding rejected prompts (if filtering) or privacy concerns regarding ID uploads (if gating).

Reporting & Record-Keeping

• The "Anti-Retention" Mandate: You are legally prohibited from retaining the identifying information used to verify age. You must configure systems to receive a "Verified" token and immediately discard the underlying data (e.g., driver's license scans).
• Safe Harbor Logs: If opting for the Safe Harbor, maintain technical logs proving your filtering systems are active and updated. These logs are your primary defense in court.
• Consent Records: If you allow the generation of sexual material, you must maintain auditable records of express consent from every individual depicted.

Fees & Costs

• Verification Costs: Expect to pay $1.00 - $3.00 per user verification if opting for the Age Gate path.
• Civil Penalties:
• $10,000 per day for operating without verification (if filters fail).
• $10,000 per instance for retaining verification data.
• $250,000 additional penalty if a minor accesses prohibited content.