When faced with a blank piece of paper it's always helpful to have a "go by," something you can use as a reference to organize your thoughts. To me, the BSA exam procedures have always been the best possible resources for developing policies and procedures. First, there is no point in inventing the wheel. Second, they will appear familiar to the regulators. Finally, even though it sounds like your attentions are "forced," there has never been a more appropriate time for banks to take a fresh look at BSA.
As you suggest, go through the exam procedures and list the major issues the policy should address. Under each major heading list the procedures that are necessary to implement the goals. Remember, policies focus on "why." Procedures focus on who, what, when, where and how.
Many banks have BSA related policies and procedures that reflect a series of documents spliced together over the last 18 years. They read and work accordingly. Yours is going to be comprehensive and reflect the current perspective on every issue.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.