Employee training

Employee training is one of the key elements in the prevention of money laundering and the financing of terrorism and forms part of the active internal control of obliged entities. Obliged entities shall ensure that their employees including employees of branches and subsidiaries, receive special training in measures against money laundering and terrorist financing and acquire appropriate knowledge of the provisions of Act no. 140/2018, regulations and rules issued on the basis thereof.

Frequency of training

The training shall take place upon commencing employment and regularly to ensure that employees know the obligations of obliged entities pursuant to Act no. 140/2018, including due diligence checks on customers and reporting obligations, as well as information on developments in the field and the latest methods of money laundering and terrorist financing.

It is assumed that general training must take place at least once a year and, as the case may be, also in special circumstances, e.g. if changes are made to the regulatory framework, risk assessment or methods of money laundering and terrorist financing. It then depends on the risk, nature and size of the obliged entity whether more specialised training is required for specific employees more than once a year.

A plan should be in place on how the training will be conducted. Such a plan should include an assessment of the need and frequency of training, e.g. by areas of activity, individual business units, types of customers or projects.

What do employees need to know?

Employees need to at least know:

  • laws, regulations, rules and, as the case may be, guidelines on the issue, e.g. with regard to the obligation to conduct risk assessments and due diligence on the basis of risk assessments, how to conduct regular inspections (in particular regarding suspicious transactions) and notifications to the person responsible and the Financial Intelligence Unit,
  • what consequences it may have for the obliged entity, its employees and the customer if rules in this area are not respected,
  • the main risks and the latest methods of money laundering and terrorist financing.

Useful links

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Business wide risk assessment Policies, controls and procedures Employee training Customer due diligence Risk assessment of contractual obligations and occasional transactions On-going monitoring Investigation and reporting requirements

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