To me, I think the confusion of whether procedures need to be approved by the Board comes from the first sentence in the "Assessing the BSA/AML Compliance Program" in the BSA/AML exam manual, which says this:
"Banks must establish and maintain procedures reasonably designed to assure and monitor compliance with BSA regulatory requirements (BSA/AML compliance program)."
When I read this, I can see how someone (speaker or examiner) could view that sentence as implying that procedures are part of the BSA/AML compliance program.
That said, I typically view the BSA/AML program as the bank's policy (and possibly risk assessment and/or other addendums) and, therefore, I've typically only seen the BSA/AML policy approved by the board, at least at smaller financial institutions. Plus, I am NOT a fan of having the Board approve procedures which may need modified more frequently than a policy which outlines general responsibilities and requirements of the program (and arguably, a bank's policy could be considered procedures - at least general procedures - in and of itself).
At the end of the day, it probably comes down to what your examiner wants, but approving every single BSA-related procedure could be challenging, and seems like a waste of your Board's time.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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