Ethics Training Under Georgian Law: What Is Actually Mandatory
Georgia has no standalone statute devoted to corporate ethics training. The mandatory core of staff training is created by the Georgian law on the prevention of money laundering and the financing of terrorism. Sub-paragraph "g" of the second paragraph of Article 29 of that law makes a continuing staff training program a mandatory component of the internal instruction, and its purpose is to deliver to employees information about the requirements of the law, the relevant subordinate normative acts and the internal instruction itself.
The code-of-conduct training and compliance-academy models familiar from United States corporate practice are not Georgian law and cannot carry a Georgian page: in Georgia, training is governed by Articles 29, 25 and 28 of the anti-money-laundering law.
Who Approves the Program and Who Answers for Its Effectiveness
The continuing training program is part of the internal instruction. The internal instruction is approved by the governing body of the accountable person or by a person holding leadership authority, which means a training program is a governance-level decision rather than the initiative of an individual manager. Under Article 29, the internal instruction must define, among other matters:
- the rights and duties of the head of the responsible person or structural unit and of its staff;
- staff selection rules for hiring persons of high qualification and reputation;
- the continuing staff training program;
- an independent audit function for checking the system’s effectiveness.
Under the same article, the position of the responsible person must correspond to the top hierarchical, management level. That person must be able to obtain, in due time, the information needed for their functions and must decide independently on submitting a report to the Service. Responsibility for effectiveness rests with a governing-body member or leadership-authority holder designated by the accountable person.
What the Training Must Cover: Suspicious Transactions and Reporting
The substantive core of the training is defined by Article 25. The accountable person must submit to the Service a report on a suspicious transaction or on an attempt to prepare, conclude or execute such a transaction. For an employee this means that the reporting duty arises not only for a concluded transaction but also for an attempt to prepare or execute one, and recognizing that moment is precisely the knowledge the training must transfer to front-line staff.
The law further contemplates that subordinate normative acts of the head of the Service may define additional types of transactions that are reportable as such, determined on the basis of information from international organizations or available to the Service. Upon request, the accountable person must submit any information obtained about a transaction or its participants, including confidential information.
Confidentiality: the Ethical Rule the Training Must Instill
Article 28 prohibits the accountable person, its managers and employees from informing the client or any other person that measures are being or will be carried out to study an unusual transaction or to detect a suspicious transaction, that a report has been or will be submitted to the Service, or that other measures defined by law are being carried out. Without training this prohibition stays on paper: staff must internalize that discussing a report with the client is impermissible.
The prohibition has statutory exceptions. Presenting information to a competent body in the manner established by Georgian legislation is not a violation, nor is dissemination of information among members of a single group where a group-level compliance control system has been introduced. The same article prohibits disclosing the identity of the employee who carries out the measures or submits the report; the accountable person must protect that employee from threats, discriminatory treatment or other unlawful influence, and no liability may be imposed on that employee for good-faith performance of the reporting duty.
Building a Continuing Training Program in Practice
The document that captures the program is the internal instruction: it defines who learns what and at what intervals. The law does not prescribe an hourly volume. The requirement is that the training be continuing and cover the law, the subordinate acts and the internal instruction itself, and that its outcome translate into a practical skill — recognizing a suspicious transaction and preparing the information needed for the report.
The effectiveness of the training system is checked by the independent audit function established by the same Article 29, which covers the entire compliance control system, training included. This lets a company demonstrate to the supervisory authority that staff are informed and the program actually operates.
Frequently Asked Questions
Below are the questions companies most often raise when preparing training documents.
Is there a separate Georgian law on ethics training?
No. The mandatory staff-training duty derives from the law on the prevention of money laundering and the financing of terrorism, whose Article 29 makes continuing training a mandatory element of the internal instruction.
Who approves the training program?
The internal instruction, of which the program is a component, is approved by the governing body of the accountable person or by a person holding leadership authority.
May the client be told that a report is being filed?
No. Article 28 directly prohibits this. Exceptions are only the cases provided by law, including dissemination among members of one group where a group-level system has been introduced.
Does the law prescribe the duration of training?
The law sets no hourly norm. The requirement is that training be continuing and address the law, subordinate acts and the internal instruction; the detailed format is defined by the company’s internal documents.
How We Help on Legal.ge
The Legal.ge team helps you prepare ethics and compliance training programs: we draft the internal instruction proportional to the nature, volume and risks of your activity and shape the continuing training blocks. Contact us whether you are creating a program or reviewing one already in place.