SAMPLE. Every institution, merchant, person, figure, hash and date in this file is invented to show the format of a review. It is not a client, a result, legal advice or a claim about any matter.

EXAMINER FILE: Lantern Row Games (example), for Harbor & Pine Bank (example)
Review R-9A4B3D, revision 2. Decision: Approved with conditions.

Sections:
  01-policies-and-procedures  Policies and procedures  [12 CFR 233.6 (policies and procedures)]
  02-account-opening-due-diligence  Due diligence at account opening  [12 CFR 233.6 (due diligence at account opening); BSA/AML customer due diligence]
  03-reasoned-legal-opinion  Reasoned legal opinion relied on  [12 CFR 233.6 (reasoned legal opinion)]
  04-review-decisions  Review decisions and reviewer independence  [12 CFR 233.6 (reasoned legal opinion); Third-party risk management]
  05-evidence-summary  Evidence summary  [12 CFR 233.6 (due diligence at account opening)]
  06-ongoing-monitoring  Ongoing monitoring and cure log  [12 CFR 233.6 (ongoing monitoring)]
  07-remedial-action  Remedial action  [12 CFR 233.6 (remedial action)]
  08-reliance-letters  Reliance letters and grants  [12 CFR 233.6 (reasoned legal opinion)]
  09-third-party-risk  Third parties in the review  [Third-party risk management]
  10-access-and-decision-log  Access and decision log  [Third-party risk management]
  11-chain-of-custody  Chain of custody
  12-evidence-integrity  Evidence integrity  [Third-party risk management]

Scope:
  - Beneficial ownership identification and verification (31 CFR 1010.230) is out of scope of this file. It is performed and kept by the institution under its own CIP/CDD program.
  - This file records the review the platform and the reviewing firm performed. The section headings say where each record belongs; they are not a conclusion that any requirement is met.
  - Breaches still inside a cure window under the institution's own materiality policy, not yet disclosed to it, are not included.
  - Evidence appears as hashes, states, counts and timestamps. No merchant source code, documents or data rows are included.
  - Records are retained for 10 years (at least the 5-year BSA record-keeping floor). A legal hold blocks deletion.

To check this file: node verify/verify-chain.mjs (see verify/README.txt).
