Table of contents
How often must AML training take place?
The law is unambiguous on this point. Under § 23(1) of Act No. 253/2008 Coll., an obliged entity must ensure that employees are trained at least once within every 12 calendar months. This is not a recommendation — it is a statutory obligation, non-compliance with which constitutes an administrative offence.
The minimum frequency is therefore once a year. You are free to train more often — and in certain situations the law explicitly recommends it (see below).
A new employee is a special case. If someone joins a position where they may encounter a suspicious transaction, they must be trained before they begin performing that work — it is not sufficient to wait for the next scheduled cycle.
Who exactly must be trained?
The law does not cover 'all employees' as a blanket rule — but every person who, in the course of their work, may encounter a suspicious transaction. In practice, for most obliged entities this means everyone who has contact with clients or processes their transactions.
Pay attention to a less obvious group: training also applies to persons who participate in the obliged entity's activities other than under a standard employment contract — i.e. those working under agreements for work, agreements for activity, external contractors or self-employed individuals — if they may encounter suspicious transactions in their work (§ 23(2) of Act No. 253/2008 Coll.).
In other words: an externally contracted estate agent or freelance accountant who handles your clients must be trained to exactly the same standard as a full-time employee.
Language barriers are not an excuse. The FAU explicitly states that a language barrier cannot justify failing to train an employee — the obliged entity must ensure training is delivered in a language the worker understands.
What must AML training cover?
Section 23(3) of Act No. 253/2008 Coll. sets out the mandatory minimum content:
- typologies and indicators of suspicious transactions
- the obliged entity's requirements for conducting client identification and due diligence (§ 7–9)
- procedures for identifying client risk factors
- procedures upon detection of a suspicious transaction — including reporting obligations
The law further requires that the obliged entity continuously supplements and updates the training content. This means the same training cannot be repeated year after year without reflecting changes in legislation or internal practice.
FAU Methodological Guideline No. 6 clarifies that training should without doubt cover the content of the internal control system (SVZ) and the entity's risk assessment — including how employees are expected to apply these in practice.
When to train outside the regular cycle?
The statutory annual frequency is the minimum. FAU Methodological Guideline No. 6 recommends conducting training outside the regular cycle in two situations:
When new products, services or technologies are introduced
Every such change brings new risks that employees must understand. A typical example: introducing online client identification or adding a new type of transaction to the portfolio.
When there is a significant change to AML regulations or new FAU methodological guidelines are issued
If the law or methodology changes substantially, it is not sufficient to wait for the next annual training. Employees must know the new rules before they start applying them in practice.
In both cases, the changes should simultaneously be reflected in updates to the internal control system and risk assessment.
How to keep training records and for how long?
The obliged entity must keep records of attendance and training content for at least 5 years from the date of training (§ 23(4) of Act No. 253/2008 Coll.).
The law does not prescribe a specific format — it permits both electronic records (e.g. e-learning output) and original signed attendance sheets. The key requirement is that records must demonstrably evidence:
- who attended the training (name, position)
- when the training took place (date)
- what the training covered
This is precisely where problems most often arise during FAU inspections. The obliged entity conducted training but has no documentation — no signed attendance sheet, no electronic record. The FAU cannot then verify that the obligation was met, and this itself constitutes a finding. Connecting training with the FAU preparation checklist and other AML workflows in a single system greatly simplifies archiving and traceability of records.
What are the penalties for non-compliance?
Failure to ensure employee training is an administrative offence under § 48(6) of Act No. 253/2008 Coll. The penalty for failing to provide training can reach up to CZK 5,000,000 (§ 48(8)). In the case of repeated or serious violations, the fine can reach up to twice the unlawfully obtained benefit or CZK 30,000,000 — whichever is higher (§ 48(10) of Act No. 253/2008 Coll.).
In practice, the FAU treats training as a standalone audit area during inspections — it wants to see attendance records, training content and the method of delivery. Missing or outdated documentation is one of the most common findings during inspections of the non-financial sector.
Important: the fine does not only apply if training never took place. It also applies if training was conducted but the obliged entity cannot prove it.
Meet § 23 and have proof — certificate, archive, dashboard
AML PROOF archives certificates for 10 years (the law requires 5 — we go further). Each certificate contains the name, role, score from all 4 modules, issue date and expiry date. During an FAU inspection, open the dashboard and present the complete team record in 30 seconds.
Frequently asked questions about AML training
How often must employees complete AML training?
Under § 23(1) of Act No. 253/2008 Coll., the obliged entity must ensure training at least once within every 12 calendar months. A new employee must be trained before they begin performing work in a position where they may encounter a suspicious transaction.
Must external contractors on temporary agreements also be trained?
Yes. Section 23(2) explicitly states that training applies to persons participating in the obliged entity's activities other than under a standard employment contract — if they may encounter suspicious transactions in their work. An externally contracted estate agent or accountant must be trained to the same standard as a full-time employee.
How long must training records be kept?
At least 5 years from the date of training (§ 23(4) of Act No. 253/2008 Coll.). Records must demonstrably evidence who was trained, when and to what extent.
What happens if training was not conducted or I have no records?
Failure to comply with the training obligation is an administrative offence under § 48(6) of Act No. 253/2008 Coll. The fine can reach up to CZK 5,000,000 (§ 48(8)). In the case of repeated or serious violations, the fine can reach up to twice the unlawfully obtained benefit or CZK 30,000,000 — whichever is higher (§ 48(10)). Equally risky is the situation where training was conducted but the obliged entity cannot prove it — the FAU requires demonstrable records.