Second Line Testing 101 – Adventures in Testing


TCAE is delighted to invite Karen Creen, CAMLO and Senior Compliance Manager at Bank of China and Saad Kiyani, Senior Manager, Regulatory Compliance Testing at BMO to share their insight on the adventures of Second Line Testing.

In this session Karen and Saad will take us through the basics of Compliance second-line testing; from identifying what to test when, to drafting a testing script, to knowing what kind of end reporting goes to who at your organization.

This presentation is applicable to both Regulatory Compliance Management testing and AML testing, and the concepts can be broadly applied to other areas considered “second line”.

Learning outcome

  • Understand the second line testing life-cycle
  • Know what makes a good testing script
  • Understand what should be included in testing reporting and why


Karen Creen, CAMLO and Sr. Compliance Manager | Bank of China

Karen Creen started in Compliance in 2003 at a Global Commercial Bank in Toronto which was the perfect entrance to a career in Compliance and AML with the release of the PCMLTFA updates mid 2004. Since that time she has held roles as Manager AML & Compliance at a retail bank and has been appointed CAMLO and Compliance Officer for two Foreign Bank Branches. Working in small teams Karen learned to multi-task and see the intersections of AML and other Compliance disciplines including Privacy and Regulatory Compliance Management. Throughout her career, she has led responses to multiple FINTRAC, OSFI and Cayman Islands Monetary Authority exams.

Saad Kiyani, Senior Manager, Regulatory Compliance Testing | BMO

Saad (rhymes with Todd) currently oversees second-line testing for all of BMO’s Canadian business units. Saad has 15 years of progressive compliance experience, moving through retail banking, corporate areas compliance, AML, and testing (including site audits).


Souzan Esmaili, Founder and Managing Director | TCAE

Souzan Esmaili has over 15 years of international experience in consultancy and training with a focus on Regulatory Compliance, Anti-Money Laundering, Anti-Bribery and Corruption and RegTech. She worked for various financial institutions and consultancies in Dubai and Toronto.

In 2019, when Souzan moved to Canada, she created TCAE with a passion to help, educate and empower Compliance & AML professionals around the world. She gained her first Canadian job experience by working as a subject matter expert on Anti Bribery & Corruption for Wells Fargo’s Canada and Latin America program.

Prior to moving to Canada in 2019, Souzan worked for various financial institutions and consultancies. In her last role as a senior consultant, she assisted her clients to understand their compliance needs, advised on meeting regulatory requirements, and managed a multitude of remediation projects. She has acted as an Authorized Individual in the capacity of Compliance Officer and MLRO for a number of firms regulated by the Dubai Financial Services Authority (DFSA).

Souzan holds an MBA from the American University of Sharjah (UAE), a Post Graduate Diploma in GRC from Manchester Business School (UK), a Certified Anti Money Launder Specialist (CAMS), FinTech Program certificate from Oxford University, and Chainalysis Cryptocurrency Fundamentals Certification (CCFC).