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The difference is that all films releases (except in private clubs) in the UK have to be submitted to the BBFC. In AMerica submitting to your film to MPAA is voluntary. They can't 'ban' films but they can give it an X cert which means it will not play at most theatres and certain stores won't stock the disk etc.
The UK also had a big back lash to Horror films after the James Bulger Murder - they tried to piggy back an new bill that so much more extreme that the 1984 VRA. Luckily it was never passed.
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