Policies, procedures and processes are a necessary part of any compliance program. An institution’s BSA/AML/CFT policy should spell out how the institution will comply with federal law/regulation. Procedures, on the other hand, are guidelines implemented by management to help personnel carry out the policy set by the Board. It’s not uncommon for us to see financial institutions getting bogged down or backing themselves into a corner with their approach to policies and procedures. We tell our clients; policies should be Board approved and “lean and mean”. Procedures, on the other hand, are where you get into the details and there should be flexibility to adjust on the fly. Thus, it makes sense to have the Board review procedures but not formally approve them.
Kevin explains more in the video.
You can find the “Policies, Procedures and Processes” article mentioned in the video on the free resources page of our website under General Tools.
Published
2025/12/1