Tonita (Toni) Gillich is Assistant Director in Forensic Audits and Investigate Service; Financial Crime Policy at the U.S. Government Accountability Office (GAO) where she has spent 17 years investigating a wide range of banking, securities, and payments system issues, focusing on work related to financial crimes for much of that time.

Toni led oversight audits of banking and securities regulators’ anti-money laundering examinations, suspicious activity reporting, settlement of banking and securities transactions, among many others. As a specialist in financial crime compliance, she has also contributed to numerous audits involving other financial crimes issues including violations of financial sanctions against Iran, mortgage foreclosure rescue scams, international remittances, maritime piracy, and cyber threats to banks. In addition to her financial crime compliance work, Toni now manages teams in GAO’s Forensic Audits and Investigative Service, where her portfolio involves examining allegations of fraud-schemes exploiting federal programs and implementation of GAO’s Framework for Managing Fraud Risk in Federal Programs by federal agencies.

Just this year Toni was a key contributor to GAO’s 60 page Report entitled “Money Laundering Risks and Views on Enhanced Customer Verification and Recordkeeping Requirements” (GAO-16-65) which was published Jan 15, 2016 and publicly Released on Feb 16, 2016. GAO was asked to examine the potential illicit uses of remittances and assess whether requiring remittance senders to provide certain types of identification at a threshold below the current $3,000 level would be useful for U.S. AML efforts. This report examined (1) BSA remittance requirements that exist for remittance providers and related challenges that remittance providers face in complying with these requirements; (2) money laundering risks that remittances pose; and (3) stakeholders’ views on the extent to which requiring remittance providers to verify identification and collect information at a lower dollar transaction amount than is currently required.

GAO launched in the summer an inquiry into the effects of banks’ increasing efforts to close high-risk accounts, including those held by money-transfer firms and humanitarian organizations. A Bipartisan Coalition sent a letter urging US regulator to address De-Risking. U.S. Sens. Jeff Flake (R-AZ), John McCain (R-AZ), John Cornyn (R-TX) and Reps. Henry Cuellar (D-TX), Juan Vargas (D-CA), Will Hurd (R-TX), Steve Pearce (R-NM), and Scott Tipton (R-CO) sent on May 26, 2016 a letter to the Treasury Department Office of the Comptroller of the Currency (OCC) Thomas Curry regarding the negative consequences that bank “de-risking” has had on businesses, financial institutions, and communities throughout the U.S., especially along the southern border where anti-money laundering regulations have led banks to simply close the accounts of customers participating in cross-border commerce to avoid or limit risk.

Before coming to GAO, she was a lobbyist for international trade and micro-finance interests. She holds a B.A. in Economics and M.A. in International Development from American University in Washington, D.C.

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