Bank Account Succession: Estate Planning for Internationally Mobile HNW Clients

The estate administration process is one of the most stressful experiences a family can face, made significantly worse when the deceased held bank accounts across multiple countries with different probate procedures, currency controls, and tax regimes. For internationally mobile HNW individuals — common among our readership — a failure to plan can mean families waiting months or years to access funds, incurring substantial professional fees, and losing value through forced currency conversions at unfavourable rates.

This guide does not replace specialist legal advice — which every HNW individual with cross-border assets should obtain. It does provide a practical overview of the issues so that clients can engage advisers from a position of understanding.

What Happens to a Bank Account on Death?

When an account holder dies, the bank account does not automatically transfer to a beneficiary. The following sequence typically applies:

1. Account frozen: Once a bank is notified of a death (usually by the executor or administrator presenting a death certificate), the account is frozen pending grant of probate or administration.
2. Probate obtained: The executor(s) named in the will obtain a Grant of Probate from the relevant court (in England and Wales, the Probate Registry). This document authorises the executor to administer the estate.
3. Assets released: The bank releases funds to the estate (not directly to beneficiaries) on presentation of the Grant of Probate and accompanying documentation.
4. Distribution to beneficiaries: The executor distributes estate assets to beneficiaries in accordance with the will or intestacy rules.

For small amounts, UK banks often release funds informally without requiring probate under the "small estates" procedure (typically up to £5,000–50,000 depending on the bank). For larger balances, probate is almost universally required.

Multi-Jurisdiction Probate: The Real Challenge

If the deceased held bank accounts in multiple countries — which is common among internationally mobile HNW individuals — a Grant of Probate from England and Wales does not automatically work in other jurisdictions. Most countries require their own probate process.

EU jurisdictions: The EU Succession Regulation (Brussels IV) has significantly simplified cross-border succession within the EU. It allows a UK national who was habitually resident in France or Spain, for example, to elect English law to govern their estate (if they are a UK national), avoiding the application of French or Spanish succession law which might impose forced heirship provisions. However, since Brexit, English Grants of Probate are no longer automatically recognised in EU member states — a separate EU probate process or re-sealing of the English grant is now required in most cases.

UAE: The UAE has a specific framework for non-Muslim expatriates, introduced through DIFC Wills and Probate Registry and Abu Dhabi Judicial Department facilities. Registering a DIFC will before death allows significantly faster estate administration for UAE assets — bank account access can be obtained within weeks rather than months. Without a registered DIFC will, UAE succession law (Sharia-influenced for Muslims; UAE Civil Code for others) may apply, creating significant delays and potentially unexpected outcomes.

Switzerland: Swiss private bank accounts require a Swiss inheritance procedure. A foreign will may be recognised but must meet specific formality requirements. The process typically involves a Swiss executor or a Swiss lawyer acting on behalf of the foreign executor, and can take six to eighteen months.

Singapore: Singapore applies its own succession law and probate procedures. Singapore accounts of deceased foreign nationals require a Singapore Grant of Letters of Administration or re-sealing of a foreign grant by the Singapore courts.

The practical implication: for each jurisdiction where you hold bank accounts, your executors will likely need local legal representation to obtain account access. The professional fees — particularly where multiple jurisdictions are involved — can be substantial, easily exceeding £50,000 for a complex multi-country estate.

Joint Accounts and Survivorship

One of the simplest estate planning tools for bank accounts is the joint account with right of survivorship. On the death of one joint account holder, the surviving holder becomes the sole account holder automatically — without requiring probate for that account.

This is a genuine simplification, but comes with limitations:

• UK: Joint accounts at UK banks typically carry survivorship rights. However, the deceased's share of the account balance is still part of their estate for UK inheritance tax purposes, even though probate is not required to access the funds.
• Tax exposure: If the joint account holder is not a spouse or civil partner, and the balance is substantial, the gift into joint names (at opening or over time) may itself have tax implications — as a potentially exempt transfer or a chargeable lifetime transfer for UK IHT purposes.
• Loss of control: Making someone a joint account holder gives them immediate access to funds during your lifetime, not just on death. This is appropriate for a spouse; it may be less appropriate for adult children.
• International accounts: Not all international bank accounts recognise survivorship rights — in civil law jurisdictions, the account may still be subject to probate regardless of joint ownership designation.

Beneficiary Designations: When They Work and When They Don't

In the United States, "payable on death" (POD) and "transfer on death" (TOD) beneficiary designations allow bank accounts and investment accounts to pass directly to named beneficiaries outside probate. These designations are powerful estate planning tools.

In the UK, this mechanism does not exist for bank accounts. English law does not recognise POD designations for current or savings accounts — the account passes through the estate. The nearest equivalent is a life assurance policy written in trust, which pays out to named beneficiaries outside the estate.

For ISAs and SIPPs, different rules apply: ISAs do not allow formal beneficiary designations but can be inherited by a spouse under the Additional Permitted Subscription (APS) rules. SIPPs allow nomination of death benefit beneficiaries who receive the funds outside the probate process. Note, however, that the long-standing inheritance tax advantage of pensions is being removed: under the Finance Act 2026, most unused pension funds and death benefits fall within the value of the estate for IHT from 6 April 2027 (deaths before that date are unaffected, and transfers to a surviving spouse or civil partner remain exempt). Personal representatives will be liable for any IHT due on the pension element.

Some US-based or international accounts may allow beneficiary designations — always check the specific account type and the applicable law.

Structuring Banking to Simplify Estate Administration

There are several practical strategies for reducing the estate administration burden for your executors and beneficiaries:

Consolidate accounts: Every additional bank account in every additional jurisdiction is another probate process. Consolidating balances where possible — while maintaining appropriate deposit insurance diversification — reduces complexity.

Maintain an account inventory: Keep a secure, up-to-date record of all bank accounts, investment accounts, and custody arrangements, with account numbers, institutions, jurisdictions, and approximate balances. This should be held with your will or accessible to your executors.

Use a private bank with multi-jurisdiction capability: Major private banks (HSBC, Citi, UBS, Julius Baer) can often facilitate estate administration for accounts held across multiple countries within their network, coordinating between local teams. This does not replace the need for local probate but can significantly speed up the practical release of funds.

Consider a single holding structure: For UHNW clients, holding investment assets through a Singapore VCC, a Jersey discretionary trust, or a Liechtenstein foundation can consolidate assets into a single structure with a defined succession mechanism, reducing the number of individual bank accounts that need separate probate processes.

Lasting Powers of Attorney: A UK LPA (for property and financial affairs) allows a named attorney to manage your bank accounts if you lose mental capacity — this is relevant during lifetime, not only on death. For international accounts, separate power of attorney documents compliant with local law may be required.

Inheritance Tax and Bank Account Location

Since 6 April 2025, UK inheritance tax (IHT) exposure is determined by residence rather than domicile. For individuals within scope, UK IHT applies to worldwide assets — including all bank accounts regardless of where they are held. The current rate is 40% on the net estate above the nil-rate band (£325,000 per individual, up to £650,000 for a married couple through the transferable nil-rate band, with the residence nil-rate band of up to £175,000 potentially on top). Holding money in a Swiss or UAE bank account does not reduce UK IHT liability if you are within scope.

For individuals who are not within scope of worldwide IHT, UK IHT applies only to UK-sited assets. Bank accounts at UK-based institutions are UK-sited assets. Accounts at foreign branches of UK banks may also be UK-sited depending on where the account is maintained — legal advice on the siting of specific accounts is important for estate planning.

The abolition of the non-dom regime (implemented from 6 April 2025) replaced domicile with a residence-based test for IHT. An individual who has been UK-resident for at least ten of the previous twenty tax years is a "long-term UK resident" and is within the scope of UK IHT on their worldwide assets, with that exposure continuing for a period after leaving the UK. This change directly affects the estate planning position of many internationally mobile HNW individuals.

Estate and succession laws are highly jurisdiction-specific and change frequently. Tax rules in particular have changed significantly in recent years. This guide provides general information only — it does not constitute legal or tax advice. Every HNW individual with cross-border assets should obtain advice from qualified solicitors and tax advisers in each relevant jurisdiction.

How Global Investments Can Help

Global Investments supports internationally mobile HNW clients in understanding the full picture of their wealth, including how banking and investment assets are structured for succession purposes. We work with specialist legal and tax advisers across the international markets where our clients hold assets and can facilitate introductions to estate planning professionals experienced in cross-border succession. Contact our team to discuss how your current banking arrangements interact with your estate planning objectives.