Policy vs. Procedures
When it comes to compliance, we tell our clients to keep Board-approved policies “lean and mean” and to let their procedures (not Board approved) fill in the details. The Board’s job is to oversee your compliance management system which essentially means they need a 10,000-foot view of your compliance efforts and not the day-to-day details of how you accomplish them. We often give the example, on the AML/CFT side, that the Board needs a general understanding of why Currency Transaction Reports (CTRs) are required, when they are required to be filed and the consequences of not doing so. What they don’t need to know is how to fill out a CTR.
In the video, Kevin discusses the distinction between policies and procedures and why it’s not a good idea to have your Board approve written procedures.
We also have an article entitled, “Policies, Procedures & Processes”, which is available in the Free Resources on our website. You will find it in the General Tools.
Published 2026/09/02
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).