Training should help workers recognise problems in their own tasks and escalate them promptly. Sending out the Act once is insufficient. Combine the statutory frequency with role assignment, service changes and examples matching your clients.
Who is trained and when
Under Section 23(1), an obliged entity must train employees whose work may involve suspicious transactions at least once during 12 calendar months. Training is also required before assignment to such a position. An annual session planned several months later does not replace a new worker’s initial preparation. Record the role-assignment date and actual training date.
Paragraph 2 also covers non-employees participating in the entity’s activities where they may encounter suspicious transactions. Actual work matters rather than the contract label. Assess external client-service staff, a collaborating office and deputies. Include an owner or manager deciding client cases in preparation appropriate to their responsibility; the word employee does not mean they need not know the procedures.
Teach decisions appropriate to the role
Statutory training covers suspicious-transaction typologies and indicators, client identification and due diligence, and associated risks. Content must be continuously supplemented and updated. An office-service receptionist needs to recognise unusual instructions and know where to escalate them. A company-formation worker also needs to understand the structure’s purpose, beneficial ownership and missing evidence. The responsible person must understand reporting and statutory distinctions, not merely application controls.
Practise three situations: inconsistent ownership information, a possible sanctions match and pressure to execute an unexplained transaction immediately. Ask workers what they record, what they still verify and whom they contact. The correct answer need not be to reject every client. They must distinguish a risk factor from suspicion and an internal pause from postponement under Section 20.
Demonstrate actual training
Section 23(4) requires attendance and content records to be retained for at least five years. Save participants, date, material version, topics and delivery method. For electronic training, link attendance to the individual and completed version. A certificate without traceable content provides weak evidence. A short practical understanding check is useful, but the Act does not prescribe one universal test format.
Assign responsibility for monitoring the next date and updating training when services, legislation or internal procedures change. Replacement dates must preserve statutory frequency. After an error, assess whether unclear instructions, an unavailable contact or lack of knowledge caused it. Translate the finding into training content and the work procedure, rather than merely obtaining another completion certificate. For each date, distinguish completion from merely sending an invitation.
Practical steps
- Map roles and external workers.
- Deliver initial and periodic training.
- Save attendance and specific content.
- Monitor dates and changes.
Illustrative scenario
A new office-service worker completes preparation before independently serving clients. They practise escalating an unclear power of attorney, and the business retains attendance and the material version.
When the situation differs
A business holds the former director’s certificate but waits until the next annual session to train a new worker.
What to document
- Role list and dates.
- Attendance and content versions for at least five years.
- Updates following procedure changes.
Common pitfalls
- Training only on application buttons.
- Excluding external workers based on their contract label.
Frequently asked questions
Does training replace internal policies?
No. Training explains how to use procedures; it cannot replace their implementation or required written form.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
Complete client information online
Where to go next
- Risk assessment and internal policies: what your business needs — Applicability, written form and exceptions for risk assessment and internal policies.
- Internal policies: adapting an outline to your practice — Turning an outline into usable staff procedures with responsibilities, escalation and evidence.
Sources and legal references
- Zákon č. 253/2008 Sb., znění od 11. 1. 2026 ↗
§ 23 odst. 1–4 · accessed 2026-10-04 - FAÚ: MP č. 11 – Hodnocení rizik a SVZ ↗
organizační opatření, školení, eskalace, příloha 1 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.