Former FinCEN Global Investigations Division Section Chief Joins Ferrari & Associates as Director of Investigations

Former FinCEN Global Investigations Division Section Chief Joins Ferrari & Associates as
Director of Investigations


Press Release

WASHINGTON, D.C. (February 3, 2020) – Ferrari & Associates, a leading U.S. sanctions law
firm, is excited to announce that Jose “Tony” Borrayo has joined the Firm as Director of
Investigations. Mr. Borrayo served close to two decades as an official in the United States
Department of the Treasury; 13 years of which were spent at the Office of Foreign Assets Control
(OFAC). During his tenure at the U.S. Treasury Department, he was responsible for identifying
and imposing sanctions against a broad spectrum of top national security threats as well as
investigating and imposing special measures with respect to foreign money laundering concerns.

During the past six years, Mr. Borrayo was a Section Chief at FinCEN’s Enforcement Division.
Under his leadership, his team designed strategies and led efforts to use Bank Secrecy Act and
USA PATRIOT Act authorities to detect and deter foreign money laundering threats to the U.S.
financial system. He also led investigations into high profile cases and coordinated extensively
with senior Treasury Officials and Federal Banking Regulators. That work included overseeing
the preparation of evidentiary packages and enforcement recommendations in key actions taken
under Section 311 of the USA PATRIOT Act such as those against North Korea, Bank of Dandong
(China), and ABLV Bank (Latvia). Furthermore, Mr. Borrayo oversaw the issuance and
preparation of a number of large Bank Secrecy Act derived ‘special collections’ requests under the
Foreign Financial Agency Regulation (31 C.F.R. 1010.360), Geographic Targeting Order (31
U.S.C. § 5326), and Demand Letter (12 U.S.C. § 1829b) authorities.

From 2003 to 2014, Mr. Borrayo served as an Enforcement Officer and Targeting Investigator at
OFAC, working in the Enforcement and Global Targeting Division. During his tenure at OFAC,
he investigated potential violations of OFAC administered sanctions programs and provided
license determinations to U.S. law enforcement regarding the admissibility of certain trade and
financial transactions. In 2005, Mr. Borrayo transitioned to OFAC’s Targeting Division where he
gained extensive experience coordinating with the U.S. State Department, Department of Justice
and Intelligence Community, and using all source information to develop sanctions designation
packages. He authored dozens of evidentiary memoranda supporting Treasury designation actions
against foreign networks tied to top national security concerns, including those linked to Iranian
and North Korean WMD proliferation networks many of which were later sanctioned by the
United Nations. Mr. Borrayo also led engagements and information exchanges with foreign
governments in connection to his investigations.

Due to his experience and understanding of OFAC and FinCEN’s mission, Mr. Borrayo often
represented the U.S. Treasury Department before foreign AML regulators and U.S. banking
institutions to share typologies of potential money laundering concern and discuss potential threats.
He was also routinely called upon to brief Congressional Committee staff on FinCEN enforcement
actions to address foreign illicit finance threats.

“Tony is a truly special addition to our team. In addition to greatly enhancing our investigative
capabilities, his background at FinCEN is unparalleled and gives our clients in the financial
services industry an unfiltered perspective as to how Treasury will view those clients’ AML and
sanctions compliance efforts.” said Erich Ferrari, the Ferrari & Associates Founder and Principal.
“Having Tony here will give our clients the ability to be on the cutting edge of compliance and
remediation and will allow them to ensure that they meet their regulators and U.S. Treasury’s

"I am thrilled to be joining the firm and help its clients navigate the increasingly nuanced sanctions
and anti-money laundering regulatory space. Ferrari and Associates have significant expertise in
assisting their clients throughout the globe and are at the forefront of U.S. and economic trade
sanctions matters” explained Mr. Borrayo. The firm will leverage Mr. Borrayo's extensive
knowledge of OFAC sanctions implementation and targeting, as well as FinCEN's unique Bank
Secrecy Act authorities. His experience conducting investigations and targeting will complement
the firm, as it continues to expand its practice.

Mr. Borrayo becomes the latest former Treasury official to join Ferrari & Associates. The Firm
seeks to be a leader in the field of U.S. economic sanctions, and Mr. Borrayo’s addition to the Firm
deepens its knowledge and experience base and expands the resources available to handle any
OFAC compliance, licensing, enforcement, or delisting matter.

202.644.9888 OFAC Representation
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