TCAE is excited to invite Laura Houlihan, Associate Director, Financial Crimes Advisory at AML RightSource to share her insights on the importance of internal AML testing programs. In this session, Laura will explain the importance of having a proactive approach to ensuring that AML/ATF policies, procedures and specific mitigating controls are adhered to. The session addresses how mistakes are common and therefore Reporting Entities must conduct ongoing testing and/or self-assessments as there can be severe repercussions stemming from deficiencies noted in an examination or audit.

During this session, Laura will also review key best practices with respect to developing and implementing AML Compliance testing programs so there are no surprises when the regulator or independent auditor arrives.


  • Why conduct ongoing testing;
  • Developing an internal testing/assessment program;
  • How to carry out the testing;
  • How to always be “exam ready”; and
  • How to ensure the Board is on-board!


Laura Houlihan, Associate Director, Financial Crimes Advisory – AML RightSource

Ms. Laura Houlihan is a passionate AML/ATF, financial crime and regulatory compliance executive professional with over 20 years in the financial industry. She serves as Associate Director in the Financial Crimes Advisory group at AML RightSource dealing with a variety of engagements and entities. Ms. Houlihan has over 15 years of AML/ATF, financial crime and regulatory compliance experience. Laura began her career as a teller at BMO Bank of Montreal and worked her way up throughout her nine-year tenure with exposure to in-branch, project management and compliance monitoring roles. In 2005, she found her calling when working at AGF Trust as Senior Compliance Specialist where she was able to develop her forte in AML and financial crime. In 2010 she became VP, Global Financial Crimes Compliance at Bank of America Merrill Lynch (Canada) where she directly reported to and supported the CAMLO. In 2014, Laura was recruited by and appointed CAMLO at an MSB where she was instrumental in developing and implementing a risk-based, OSFI and FINTRAC-compliant AML/ATF compliance program which assisted in successfully obtaining approval to continue business as a Schedule 1 financial institution now known as Exchange Bank of Canada. Since 2016, Laura has held key executive leadership roles in the capacity of Chief Compliance Officer and CAMLO where she acted as subject matter expert on a wide array of complex AML, financial crime and regulatory compliance matters.

She graduated with an Honours Bachelor of Arts specializing in business and political science from Wilfrid Laurier University. Laura has held the Certified Anti-Money Laundering Specialist (CAMS) designation for over 10 years, is a Certified Cryptocurrency Investigator (CCI) and is a regular speaker at industry events. Laura is also a Fellow and mentor for the Twelve Program and an active member of the Canadian MSB Association.



Souzan Esmaili, Compliance & AML Consultant | Founder, 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 Toronto, she worked with one of the international banks and covered their Anti-Bribery and Corruption program for Canada and Latin America.

Prior to moving to Canada, Souzan worked as a senior consultant and assisted her clients to understand their compliance needs, advised on meeting regulatory requirements and managed a multitude of remediation projects.

She has acted as the Compliance Officer and MLRO for a number of firms regulated by the Dubai Financial Services Authority (DFSA) and advised extensively on matters related to Governance, Risk and Compliance (GRC).

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