I my bank does not open accounts for commercial/ busienss customers do I need a policy for Reg GG?

Are we supposed to have a policy for Reg GG even if we open accounts for commercial/business customers? We don't have a policy but we ask a question in regards to this at account opening.

Sec. 233.5 Policies and procedures required

(a) All non-exempt participants in designated payment systems shall establish and implement written policies and procedures reasonably designed to identify and block or otherwise prevent or prohibit restricted transactions.