Federal record-keeping exemption notice
18 U.S.C. 2257 Exemption
Last modified August 7, 2026
This page sets out the position of OCAI LTD ("HoneyPot," "we," "our," or "us") with respect to the federal record-keeping requirements of 18 U.S.C. § 2257 and 28 C.F.R. § 75.
Summary
HoneyPot is an AI companion platform. All sexually explicit content on honeypot.com is generated by artificial-intelligence systems in response to user prompts. It does not depict any actual human being engaged in any sexually explicit conduct.
Because 18 U.S.C. § 2257 and 28 C.F.R. § 75 apply to visual depictions of actual human beings engaged in actual or simulated sexually explicit conduct, the record-keeping requirements of those provisions do not apply to AI-generated images and videos produced through the Services.
Our Position
- Every AI-generated image, video, and text produced through the Services is created by software in response to user prompts and reference data. The output does not depict any real person engaged in actual sexually explicit conduct
- Honeys ("AI Companions") and their generated content are entirely fictional characters and do not represent any specific individual
- Users cannot supply their own photographs to the generation pipeline. Image-editing renders accept only media that the Services themselves generated and that already passed pre-generation screening, so no user-supplied photograph of a real person can be used as a generation input
- All AI-generated visual depictions on the Services depict fictional characters who are unambiguously 18 years of age or older
What We Still Do
Although 2257 does not apply to AI-generated content, we still take robust steps to ensure safety and lawful operation:
- Age-gate at registration; users must affirm they are 18+ (see Underage Policy)
- Strict prohibition on content involving minors or that resembles a minor (see Prohibited Content Policy)
- No user-supplied photographs as generation inputs: image-editing renders accept only media the Services generated themselves, and the only file a user can upload anywhere is a profile photo
- Pre- and post-screening of every prompt, configuration, and generation (see Pre-Screening and Post-Screening Policy)
- Mandatory reporting of any apparent child exploitation material to NCMEC, in line with 18 U.S.C. § 2258A
Records Custodian
Should the position above ever cease to apply to specific content (for example, if the Services were to host visual depictions of actual human beings engaged in sexually explicit conduct in the future), the records required under 18 U.S.C. § 2257 would be maintained by the Records Custodian designated by the operator of HoneyPot, whose current contact details are available on request at support@honeypot.com.
OCAI LTD
Attn: Records Custodian
Nicosia, Cyprus
Contact
For questions about this notice, write to support@honeypot.com.
OCAI LTD
Nicosia, Cyprus