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FBI Agent Addresses 2257 Inspections

HOLLYWOOD, Calif. — There are over 1200 adult companies in The Naked City and any one of them could be eligible for an FBI 2257 inspection.

The Bureau is working from a constantly updated database of companies, and that was the word today in Hollywood. FBI special agent Chuck Joyner, speaking only as an inspection agent, addressed an adult industry audience of 350 [according to XBiz] at the XBIZ Hollywood ’07 Industry Conference. And Joyner put out the word to expect more inspections with a beefed up enforcement team in 2007.

To date, The feds have visited 10 porn companies and only two have passed without violations, according to Joyner. Although 2257 regulations have been in place since November 18, 1988, no adult companies had been inspected until this past year when new rules extending to secondary producers went into effect June 23, 2005.

According to Joyner who answered written questions from the audience, the FBI has been choosing its inspections randomly and is not targeting specific companies in an effort to determine whether minors were involved in the making of videos.

Joyner said the FBI is looking for intent. And companies so far have been cooperative and professional.

The FBI uses both a spreadsheet system that includes names of models, birth dates, [digital copies of IDs such as PDF files are acceptable forms of identification], their films and a checklist cross referencing alternate names of models. After making a preliminary report, the FBI allows the company a one-week period to respond if inaccuracies or insufficient information is uncovered before filing an official report that could be sent to the U.S. Attorney’s office.

Failure to cross reference names of models with their stage names, bad photocopies of records and missing records with no photo identification are common violations. But an effort to resolve those violations won’t result in prosecutions.

Joyner said the FBI would like to make the inspection process as transparent as possible and that companies in violation should expect a re-visit within four months. Joyner also noted that a custodian of records does not have to be present at the place of business at all times during the business week.

“You just have to post when your hours are, so we know when to come back,” he said, noting that allowances are also made for holidays. During the discussion, Joyner also conceded that the FBI has no jurisdiction over foreign-based companies.

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