BSA Officer David Hazen advised the FRB, that the business division is still unclear of what transactions are allowable for the Ho Chi Minh and Mega ICBC Manila branch’s to perform; and continue to attempt to submit transactions from Ho Chi Minh and Manila to the BSA officer for approval, that are not the already pre-approved transactional types as they under specific BICs. David further advised that due to the NYB’s need to continue to de-risk the bank, he will be presenting complete disallowance of all transactions for Ho Chi Minh and Manila to the GM and Chairman in Q1 2020 and the regulators agree with the aforementioned decision.