Concept
A foreign account does not automatically pass to heirs upon the owner's death—it is frozen. The bank will only unblock it for those who prove their rights according to its rules, which means in another country, in another language, and under a different procedure.
🍓 A foreign account is frozen upon the owner's death; the bank will only unblock it upon presentation of its required succession documents. Joint accounts and designated beneficiaries simplify access.
Freezing and Access
Upon learning of the death, the bank blocks the account until succession documents are provided—a local certificate, grant of probate, or European Certificate of Succession. Without the correct document in the correct form, the funds remain "frozen" for months.
Brokerage Portfolios and US-situs
A special case is a brokerage portfolio containing US stocks: these are assets with US-situs, and in addition to access issues, there is a risk of US estate tax (up to 40% above $60,000), even if the broker is European and the owner is a non-US resident.
⚙️ A joint account with right of survivorship and payable-on-death beneficiary designation in many countries provide access outside of probate proceedings—but not everywhere and not for all account types.
How to Simplify
🔗 Related
US estate tax · Succession to Foreign Real Estate · US Estate Tax · European Certificate of Succession · Crypto and Digital Asset Inheritance
Tools include a pre-compiled map of accounts with details and contacts, joint accounts and designated beneficiaries where they work, and for large portfolios, a holding company or trust that owns the account, so that upon death it is not the account owner that changes but control within the structure.
💡 The US-situs risk for US stocks is addressed separately: see US estate tax.
This material is for informational purposes only and does not constitute individual legal advice.
Key factual claims
- A special case is a brokerage portfolio containing US stocks: these are assets with US-situs, and in addition to access issues, there is a risk of US estate tax (up to 40% above $60,000), even if the broker is European and the owner is a non-US resident.