# Onboarding checklist: Verified Opinion

_[Institution]’s merchant onboarding team. Version 2026-10-07.1._

> Template for the institution’s own counsel to adapt. Not legal advice, not tailored to any institution, and no attorney–client relationship is created by using it. Apparently Law reviews opinions only for the relying institution and never advises the merchant whose opinion it reviews.

| # | Step | Who | What proves it |
|---|---|---|---|
| 1 | Classify the merchant as in scope and list each product and jurisdiction requested. | Merchant Risk | Scoping record in the onboarding file |
| 2 | Receive the merchant’s legal opinion, drafted and signed by its own counsel. | Merchant | Opinion document, hashed on receipt |
| 3 | Engage independent reviewing counsel for [Institution] and confirm it has no engagement with the merchant on the subject. | Merchant Risk | Engagement letter and independence attestation |
| 4 | Merchant links its repository, database and public documents, read-only, through the designated evidence tools. | Merchant | Linking checklist with each source verified |
| 5 | Every fact in the opinion is tested against the merchant’s systems and ranked measured, stated or inferred. | Reviewing counsel | Facts-against-evidence register |
| 6 | Findings are delivered: product fixes to the merchant, reasoning gaps to the merchant’s own counsel. | Reviewing counsel | Finding register with tiers and owners |
| 7 | Each resubmission is checked against the previous round, with proof for every fix. | Reviewing counsel | Round-over-round comparison |
| 8 | Reviewing counsel decides, scoring each section of the opinion and stating any conditions with an owner and a date. | Reviewing counsel | Signed decision |
| 9 | Enable only the jurisdictions the decision covers. Hold the rest. | Merchant Risk | Enablement record, by jurisdiction |
| 10 | Record the reliance grant and file the sealed review record in the examiner file. | Merchant Risk | Reliance grant; examiner file manifest sha256 |
| 11 | Turn on continuous monitoring and diarise the bring-down date. | Merchant Risk | Monitoring enabled; bring-down date |
| 12 | Confirm beneficial ownership under [Institution]’s own CIP/CDD program. | BSA Officer | CIP/CDD record (outside the review) |