Email shows CNI urged FinCEN to issue second advisory on Banca Privada d’Andorra

An email included in several Spanish court cases and now in the investigation into a suspected attack on Andorran sovereignty indicates that Spain’s intelligence service, the Centro Nacional de Inteligencia (CNI), sought to persuade the US Treasury’s Financial Crimes Enforcement Network (FinCEN) to issue a second advisory note on Banca Privada d’Andorra (BPA) after the bank’s intervention. The message, sent six days after the intervention of BPA and its Spanish subsidiary, urged renewed action to prevent the bank from “raising its head.”

Former police commissioner José Manuel Villarejo, who received the email, confirmed its authenticity in testimony before the judge handling the so‑called “Rajoy case.” In court he refused to disclose the identity of the sender, citing Spanish penalties for revealing sensitive information. He told the judge the correspondent signed as “Tomàs,” an apparent alias, and denied that the sender was CNI director Fèlix Sanz Roldán, whom he said never spoke with him directly.

The email conveys frustration within the CNI with Villarejo for not following the line set by state leadership and for publicly asserting that then‑King Juan Carlos and the Pujol family had funds at Andbank. The correspondent reportedly argued that investigation should focus on a different Andorran institution rather than BPA, and worried that BPA executives might mount a defense that would expose information.

According to the message, the CNI’s usual liaison with FinCEN, Guardia Civil commander Basilio Sánchez Portillo, was unavailable at that time because he was attending professional training. Sánchez Portillo had previously acted as the link between Spain and FinCEN and had provided, among other material, financial intelligence reports from Sepblac on BPA. The email records that, because Sánchez Portillo could not undertake new démarches, contacts urged that Villarejo use his own connections — specifically an alleged “friend” at the FBI, Marc Varry, who served as the American law‑enforcement link at the US embassy in Madrid — to push FinCEN to issue a second note that would “finish off” BPA.

Spanish courts later found that both Banco Madrid and BPA had anti‑money‑laundering mechanisms appropriate to, and even exceeding, the regulatory requirements in force at the time of the intervention. The email reflects concern at the time that renewed pressure on FinCEN was deemed necessary to protect the outcome of the intervention and to restore confidence among senior police, political and intelligence officials in those who had handled the case.