Tony Borrayo

Mr. Borrayo joined Ferrari & Associates after almost two decades working at the U.S. Treasury Department on both sanctions and money laundering issues.

Prior to joining the firm, Mr. Borrayo spent five years at the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) as Section Chief of the Enforcement Division’s Office of Special Measures. During his tenure, he proposed strategies and oversaw investigations aimed at limiting foreign money laundering threats from accessing the U.S. financial system. Mr. Borrayo led investigations resulting in the successful execution of numerous actions imposed under Section 311 of the USA PATRIOT Act targeting foreign jurisdictions, including DPRK and Iran, and financial institutions, including ABLV Bank. He managed the administration of FinCEN’s special information collection authorities provided to FinCEN under the Bank Secrecy Act, including the Geographic Targeting Order and Foreign Financial Agency regulations. Mr. Borrayo ensured that these efforts contributed to ongoing investigations and advanced the U.S. government’s understanding of current and over the horizon illicit finance threats.

As a seasoned expert in FinCEN’s authorities, Mr. Borrayo was routinely called upon to brief Congressional Committee staff, such as Banking and Foreign Relations, with respect to FinCEN administered authorities used to target foreign illicit finance threats.

Prior to his tenure at FinCEN, Mr. Borrayo spent over a decade at the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) in the Enforcement Division.  Starting in 2003, he investigated potential violations of OFAC sanctions programs, and provided guidance to law enforcement on the admissibility of international trade transactions – which contributed to the execution of both OFAC civil enforcement actions and criminal matters.

In 2005, Mr. Borrayo transitioned to OFAC’s Targeting Division where he conducted all source investigations and proposed designation actions related to high priority national security threats.  His portfolio included investigations into elaborate nuclear and ballistic missile procurement networks utilized by Iran and DPRK and authoring evidentiary memoranda in support of designation actions issued by OFAC.  Mr. Borrayo worked closely with other U.S. government agencies and U.S.-allied governments in support of the multilateralization of certain targeted U.S. sanctions programs. His collaboration contributed to the successful adoption of the United Nations Security Council Resolutions designed to address Iran and the DPRK’s weapons programs.  Mr. Borrayo played a pivotal role in informing senior policy makers with regards to key financial vulnerabilities related to foreign adversaries and “over the horizon” threats.  His ability to identify these vulnerabilities contributed substantially to Treasury’s successful outreach efforts to isolate Iran’s illicit finance networks.  In addition, he made significant contributions in scoping Executive Orders and Congressional laws by enhancing their Targeting utility and ensuring they can be utilized effectively. 

As Senior Director of Investigations at Ferrari and Associates, Mr. Borrayo leads efforts in conducting due diligence investigations on a variety of matters.  This includes supporting the Firm’s advisory services and assisting international clients with respect to sanctions compliance issues and pre-transactional due diligence and investigations into third party vendors, intermediaries and supply chain actors.  Mr. Borrayo’s wealth of Treasury experience also provides the Firm unique insights and significant added value in connection to its work with clients who are seeking to be removed from the OFAC SDN list.

Representative Matters

• Augmented sanctions and anti-money laundering policies and procedures for a U.S. based crowdfunding platform with significant global touchpoints. Developed enhanced due diligence forms and sanctions screening and escalation procedures.
• Developed supplemental sanctions and anti-money laundering procedures for a mid-size European financial institution. Designed a guide containing risk factors to consider when assessing whether transactional information implicates a U.S. sanctions or money laundering concern.
• Conducted sanctions risk assessment for a major African based commodities entity. Reviewed its operations and transactions, identified vulnerabilities, and recommended measures to rebut adverse news media and minimize sanctions exposure.
• Serve as a subject matter expert on Firm’s ongoing OFAC sanctions delisting matters. Investigating underlying allegations and gathering factual evidence to identify the root of sanctions concerns, including reviewing and evaluating transactional information pertaining to supply chain and customers; analyzing corporate organizational and ownership structures; conducting interviews and preparing questionnaires; and identifying areas that need remediation and/or information that could be used to negate the basis for the sanctions.