A review that checks whether the facts are true.
Are the facts true? Are they still true? Can you prove you checked? Seven published tests.
Draft 0.1, October 2026.
What each review checks
- A review of the opinion aloneA review under the Standard
- The reasoningChecked against its own citations.Checked against every authority, every state.
- The factsTaken on trust.Tested against the system.
- What it leaves outInvisible.Found and flagged.
- After signingFrozen at its date.Re-checked hourly.
- The recordA letter.A sealed, verifiable file.
- IndependenceVaries.Never for the merchant.
The seven tests
1The reasoning holds
Every conclusion traced to its authority, state by state.
2The facts are true
Each fact tested against the merchant’s own systems.
3Nothing is left out
What the system does that the opinion never mentions.
4It fits your reliance
Read against your own onboarding standard.
5The reviewer is independent
Never engaged by the merchant under review.
6There is a record
Every step hashed, dated, signed and sealed.
7It stays true
Re-checked continuously, with a 12-month bring-down.
The Standard, applied
Counsel scores each section against the measured facts.

Example data: invented bank, people and figures. Not a client or a result.
How evidence is ranked
Measured
Seen in the system. The only rank that clears a state.
Stated
Asserted by the merchant, not observed.
Inferred
Reasoned from other facts. Never relied on.
Only a measured fact clears a state.
What the Standard is not
- Advice to the merchant. We review only for the institution.
- A substitute for the merchant’s own counsel, who drafts and signs.
- A machine verdict. An attorney decides and signs.
- A guarantee. It records what was tested, and when.
Adopting it
Require it in your merchant agreements. Sample language, not advice:
Any legal opinion a gaming merchant delivers to [Institution] in support of its application or continued account shall be a Verified Opinion: reviewed for [Institution] under the Verified Opinion Standard, with each fact on which the opinion relies tested against the merchant’s systems and the review record delivered to [Institution].
A draft. Comments to team@apparently.cc. Get the full kit.
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. Facts are tested on Apparently AI’s platform; the attorney decides. Apparently AI and Apparently Law are under common ownership — disclosed affiliation, not an independent recommendation.




