This lovely regulation applies exclusively to the production of sexually explicit conduct, not mainstream, non-adult content -- unless said sexually explicit conduct happens to be conveniently exempted under 4472 thanks to the bought-and-paid-for loopholes created for Hollywood and the television industry.

So if you're an English (or Canadian) actor who is not appearing in actual (or now, simulated, thanks to 4472) sexual conduct, or you are appearing in actual or simulated sexual conduct produced by a major television network or hollywood studio (the language is slightly more obtuse, but means the same thing) then you do not have to, under 2257, have a green card in order to be compliant.

For mainstream entertainment performers who are citizens of other countries, work visas for theatrical performers coming over for temporary visits (think bands, for example) are very easy to get. Porn performers probably not so much.

The US law does *not* require that US citizens (or US-based producers) shoot content in the US; the correspondence between FSC and DOJ clarified last year that the vague phrase "located outside the US" contained in the regulations means, in so many words, "where your feet are planted at the time the content is shot" and does not refer to country of residence.

So, for example, you could have a Canadian, a Mexican, and a French model, shooting content in Toronto, with a US-based producer/director and American and Canadian videographers, and be OK (at least with US regs) but you could not bring the Canadian, Mexican and French models into the US and shoot the scene there, under the current regulations.

At least as I understand it. Your mileage may vary.

Pierre, your best bet for now is to shoot your scenes in Canada. We have several Canadian models that we're now doing that with. I'm not sure about the US ID thing; I believe what Lee says is correct that you can get one with a Canadian passport, but I'm not as clear, in light of what Chad just said, on whether that US ID would be permissible as far as 2257/4472. I've emailed Chad for a clarification.