Every review, ready for the examiner.

Every review comes with a file you can check yourself, without trusting us or the bank.

Sample examiner file Sample sealed record

An example agency’s book on the regulator site, with its side rail: every gaming opinion it holds, weakest first, with the operator, law firm, bank and processor behind each; then the banks ranked by their opinions’ scores against its standard. — Example data: invented bank, people and figures. Not a client or a result.

The examiner file

Filed under the headings examiners use. The conclusions stay yours.

Policies and procedures12 CFR 233.6 (policies and procedures)
Due diligence at account opening12 CFR 233.6 (due diligence at account opening); BSA/AML customer due diligence
Reasoned legal opinion relied on12 CFR 233.6 (reasoned legal opinion)
Review decisions and reviewer independence12 CFR 233.6 (reasoned legal opinion); Third-party risk management
Evidence summary12 CFR 233.6 (due diligence at account opening)
Ongoing monitoring and cure log12 CFR 233.6 (ongoing monitoring)
Remedial action12 CFR 233.6 (remedial action)
Reliance letters and grants12 CFR 233.6 (reasoned legal opinion)
Third parties in the reviewThird-party risk management
Access and decision logThird-party risk management
Chain of custody—
Evidence integrityThird-party risk management

Harbor & Pine Bank’s Portfolio: every applicant ranked, in its lane, with its review clock and tier, and one applicant opened to its timeline. — Example data: invented bank, people and figures. Not a client or a result.

Harbor & Pine Bank’s Portfolio: every applicant ranked, in its lane, with its review clock and tier, and one applicant opened to its timeline. Step 1: Every applicant, ranked by what needs you first. — Example data: invented bank, people and figures. Not a client or a result.

How evidence is checked

Built to be checked, not trusted.

1Read-only
Nothing written. No rows leave the merchant.
2Measured, not copied
References and hashes, never code.
3Hashed on arrival
Any later change shows as a new hash.
4Signed at the source
Evidence sits under a signed hash chain.
5Chained
Every decision is a link. Tampering breaks it.
6Re-measured
Hourly, after approval.
7Verifiable without us
One script recomputes every hash.
8Kept 10 years
Beyond the 5-year BSA floor.

Check the sample yourself

unzip sample-examiner-file-lantern-row.zip
cd sample-examiner-file-lantern-row
node verify/verify-chain.mjs

VERIFIED: 17 files, 7 events, chain head 9

Node 18+, no dependencies. Sample data only.

R-3 Lantern Row Games in the bank’s Portfolio: each fact in its legal opinion set against what was measured in its code, database and public documents, with a verdict. — Example data: invented bank, people and figures. Not a client or a result.

Detect, flag, act, raise the bar

Stop weak opinions from carrying unlicensed gaming into your state.

The regulator workspace is Apparently AI software. Apparently AI and Apparently Law are under common ownership — disclosed affiliation, not an independent recommendation.

Every institution, one list

Every bank and processor behind your opinions, weakest first.

An example agency’s institutions: each bank and payment processor behind the opinions it holds, how many gaming opinions each relies on, how many fall short of the agency’s standard, the weakest score and the operators behind them. — Example data: invented bank, people and figures. Not a client or a result.

No license on record

Unlicensed operators, state by state, on your own assumptions.

An example agency’s unlicensed-exposure estimate: by state it supervises, operators named in its opinions with no license found in our records, and estimated revenue at stake only where the agency set its own assumption. — Example data: invented bank, people and figures. Not a client or a result.

Weak opinions, flagged and cited

Each flag quotes its passage. Your attorney decides.

One example opinion as the agency opens it: its screen band and score, its most serious flags against the agency’s standard, and the passages of the opinion each flag cites. — Example data: invented bank, people and figures. Not a client or a result.

The institution acts, on the record

Direct a bank to act, and track its answer to done.

Directives are for banking and money-transmitter regulators. Gaming regulators can issue notices to cure.

An example agency’s directives: one to a bank to stop relying on an opinion, waiting for its acknowledgement; one to challenge an opinion, which the bank is acting on, open to its answer; and one to a processor to stop serving a state, done. — Example data: invented bank, people and figures. Not a client or a result.

Raise the bar to RLO Plus

Start from our standard and make it stricter, never looser.

An example agency’s review standard: the version in force and its hash, and the checklist with the items the agency raised above the baseline and the locked non-negotiables. — Example data: invented bank, people and figures. Not a client or a result.

Built for how an agency works

Your attorney confirms
Nothing leaves without a second attorney.
Your records only
Only your states. Nothing flows out.
A signal, not a conclusion
Every result is labeled a screen.

The advisory board

Senior banking regulators and gaming attorneys. Members named once confirmed.

Banking regulators
Former federal and state supervisors.
Gaming attorneys
Sweepstakes, skill, fantasy, prediction markets.
Public revisions
Every change to the Standard, on the record.

Questions: team@apparently.cc. Read the Standard.

Your standard, on every gaming opinion.

Talk to us

Available to agencies by arrangement. Attorney advertising. This site is informational and is not legal advice. Using it, or sending information through it, does not create an attorney–client relationship. That relationship begins only when a written engagement letter is signed by both sides. Every engagement is performed by an attorney licensed in the relevant jurisdiction.