Tony Borrayo serves as Technical Advisor at Sanctions Law Center, where he advises on complex sanctions, anti-money laundering, illicit-finance, and enforcement matters. Drawing on nearly two decades at the U.S. Department of the Treasury, he brings particular expertise in sanctions investigations, financial intelligence, and illicit-finance enforcement.

Before joining Sanctions Law Center, Tony spent five years at the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) as Section Chief in the Enforcement Division's Office of Special Measures, where he led investigations and developed strategies targeting foreign money laundering threats and financial institutions. He previously spent more than a decade at the Office of Foreign Assets Control (OFAC), working on sanctions targeting, investigating potential sanctions violations, and supporting civil enforcement actions and criminal matters.

During his tenure at FinCEN, Tony led investigations resulting in numerous actions under Section 311 of the USA PATRIOT Act targeting foreign jurisdictions and financial institutions, including matters involving North Korea, Iran, and ABLV Bank. He also managed the administration of FinCEN's special information-collection authorities under the Bank Secrecy Act, including Geographic Targeting Orders and Foreign Financial Agency regulations.

Through this work, Tony helped advance investigations and strengthen the U.S. government's understanding of emerging and evolving illicit-finance threats.