Building and Maintaining a Multi-Jurisdiction Asset Register

The administration of a deceased person's estate is, in all jurisdictions, a process of discovery. Executors must identify what assets exist, where they are held, what they are worth, and how legal title passes to the intended beneficiaries. For a person whose entire estate consists of a UK house, a UK bank account, and a UK investment portfolio, this process — while never easy — is at least straightforward. For internationally mobile individuals whose assets are spread across five countries, held through a combination of direct ownership, trust structures, company shareholdings, and pension arrangements, the process without a comprehensive asset register can take years and destroy significant value in the process.

This guide explains what a multi-jurisdiction asset register is, what it should contain, how it interacts with probate and succession planning, and the practical steps for creating and maintaining one.

What is an Asset Register?

An asset register is a comprehensive, structured record of all the assets (and significant liabilities) held by an individual, including:

• What each asset is
• Where it is located or held (physically and legally)
• How legal title to it is held (sole ownership, joint ownership, trust, company)
• Current approximate value
• The account numbers, reference numbers, and contact details needed to access or transfer it
• The succession arrangements that apply to it (will, trust, company articles, beneficiary nomination)

An asset register is not a legal document — it does not transfer title to anything, and it does not override the provisions of a will or trust deed. Its purpose is practical: to ensure that executors, trustees, and advisers can identify, locate, and administer assets efficiently after death or incapacity.

Why Internationally Mobile Individuals Need One Urgently

For most UK residents with simple asset structures, the absence of an explicit asset register is an inconvenience to their executors but not a disaster. Bank accounts can be traced through bank statements; investment accounts have providers who will respond to executor enquiries; property is registered and can be searched.

For internationally mobile individuals, the position is very different:

Assets may be held in jurisdictions where executors have no connections. A UK executor administering a UK estate does not automatically have the authority to deal with assets in Thailand, Cyprus, or the UAE. Local probate processes may be required. Without knowing the asset exists, the executor cannot even begin that process.

Assets held through offshore companies and trusts are not obvious. A BVI holding company owning a property in the UAE is not visible from a search of either UK or UAE property registers. Without documentation of the structure, even experienced advisers may not know it exists.

Pension and life insurance arrangements have named beneficiary nominations. If the nominee is out of date — an ex-spouse, a deceased parent — the asset may pass to the wrong person or into the estate unexpectedly. The only way to ensure nominations are current is to have a systematic record of them.

Digital assets are frequently invisible. Cryptocurrency holdings, online investment accounts, and digital payment balances can be permanently inaccessible if the login credentials and recovery information are not documented and accessible to executors.

Professional and family advisers change. A deceased person's family may not know who their tax adviser, investment manager, or pension trustee was. Without a central record, locating and liaising with each adviser takes time and sometimes years.

Situs Rules: Why Location Matters

Understanding where each asset is legally located — its situs — is important because succession law typically applies different rules to assets in different jurisdictions:

• Land and buildings: sited where physically located — always governed in the first instance by the law of that country
• Company shares (registered companies): sited where the company's share register is kept — UK registered companies have UK situs regardless of where the shareholder lives
• Bank accounts: typically sited at the branch where the account is held
• Moveable chattels: sited where they are physically located at the time of death

For assets in multiple countries, separate grants of representation may be required in each jurisdiction. A UK Grant of Probate is not automatically recognised in Spain, France, the UAE, or Thailand. "Resealing" the UK grant in Commonwealth jurisdictions (Australia, Canada) is possible but still requires formal procedures. In other jurisdictions, a local grant must be obtained entirely independently.

An asset register that records the situs of each significant asset allows executors to identify, at the outset, in how many jurisdictions they will need to obtain representation — and to engage local lawyers in each jurisdiction promptly.

What the Asset Register Should Contain

A comprehensive multi-jurisdiction asset register should address:

Real Estate

For each property:

• Full address and country
• Current estimated market value and date of valuation
• How title is held: sole name, joint ownership (and in what shares), through a company, through a trust
• Mortgage or other borrowing secured on the property — lender, account number, current outstanding balance
• Title documents location (particularly important for overseas property where paper title documents may be held by a local lawyer)
• Local lawyer or notary contact details
• Rental management company contact if tenanted
• Succession arrangement: direct (will), company shareholding, trust

Bank and Financial Accounts

For each account:

• Institution name and country
• Account number and IBAN/SWIFT where applicable
• Approximate balance (updated regularly — at least annually)
• Currency
• Whether the account is in sole name or joint names
• Online banking login information or how to access it (see below on digital credentials)
• Whether the account is within a trust or company structure

Investment Portfolios

For each portfolio or investment account:

• Platform or manager name and contact
• Account reference number
• Current value and date of last statement
• How assets are held (direct ownership, within a SIPP, within an offshore bond, within a trust, within a company)
• Death benefit nominations where applicable

Pension Arrangements

For each pension:

• Scheme name and type (DB or DC)
• Administrator contact details and reference number
• Current fund value or projected benefit
• Normal retirement date and access age
• Expression of wishes / death benefit nomination: who is nominated, and when was it last reviewed?
• Whether this is a SIPP, QROPS, occupational scheme, or personal pension
• Country of establishment

Life Insurance and Protection Policies

For each policy:

• Insurer and policy number
• Type: term assurance, whole of life, critical illness, income protection
• Sum assured and expiry date
• Whether written in trust (and if so, which trust, and who are the trustees)
• Premium and payment date
• Contact details

Business Interests

For each shareholding or business interest:

• Company name, company number, jurisdiction of incorporation
• Nature of interest: ordinary shares, loan notes, partnership interest
• Approximate value or last agreed valuation
• Whether subject to a shareholder agreement or articles restricting transfer
• Key contact: company solicitor, accountant, co-shareholders

Trust Interests

For each trust in which the individual has an interest (as settlor, trustee, or beneficiary):

• Trust name and jurisdiction
• Trustee contact details
• Nature of interest (discretionary, fixed, life interest)
• Approximate trust fund value
• Copy of the trust deed — or its location

Offshore Company Interests

For each offshore company:

• Company name and registration number
• Jurisdiction
• Registered agent contact
• Nature of shareholding and any restrictions
• Assets held by the company
• Copies of incorporation documents — or their location

Digital Assets

For each significant digital holding:

• Type: cryptocurrency, online investment account, digital payment balance
• Platform name
• Approximate value
• How to access it: wallet address, exchange login, recovery phrase (the security of this information requires particular care)

Cryptocurrency in particular can be permanently inaccessible if the private keys or recovery phrases are not documented and securely stored.

Digital Credentials: The Security Problem

The most sensitive part of an asset register is the record of login credentials and passwords. A document containing account numbers, login details, and recovery phrases for all financial accounts is an enormously attractive target for theft or fraud.

Balancing accessibility with security requires thought:

• The asset register should be stored in encrypted form — a password manager (such as 1Password or Bitwarden) can store it securely, with the master password held by a trusted family member or solicitor
• Some individuals maintain a sealed envelope with the master password deposited with their solicitor, to be opened only on death or incapacity
• For cryptocurrency, recovery phrases should be stored in multiple secure physical locations — they should never be in a single location that could be lost or destroyed

The instinct to avoid writing down financial credentials should be overridden for estate planning purposes. An executor who cannot access digital accounts is not protected by the fact that the information was never written down — they simply cannot administer the estate.

The Executor Briefing Letter

Complementary to the asset register is an executor briefing letter — a document addressed to the named executors that explains:

• Where the asset register is held and how to access it
• The identity of key advisers (solicitor, financial adviser, tax adviser, investment manager) and their contact details
• The location of important documents: will, passports, trust deeds, property title documents
• Any time-sensitive matters (property insurance that needs renewing, a loan facility due for renegotiation)
• Any matters the deceased wishes to explain or that require context

The letter should be updated whenever circumstances change and its location communicated to executors.

Keeping the Register Current

An asset register that is five years out of date is better than no asset register, but it can mislead executors who trust its contents without checking. A discipline of annual review — timed to coincide with the annual financial review described elsewhere in our guide series — ensures the register remains accurate.

Events that should trigger an immediate update:

• Acquisition or disposal of any significant asset
• Opening or closing any financial account
• Change of pension or insurance nomination
• Change in how an asset is held (moving from direct ownership to a company or trust)
• Change of any key adviser or their contact details

How Global Investments Can Help

Global Investments provides consolidated reporting services that aggregate financial accounts across multiple jurisdictions and asset classes into a single view. This consolidated report can form the basis of — or a complement to — a comprehensive asset register.

We also work with estate planning solicitors and trust professionals to ensure that the succession arrangements recorded in your asset register are properly implemented in legal documents, and that expressions of wishes with pension trustees and life insurance nominations are current and consistent with your overall estate planning.

We recommend that all clients maintain an up-to-date asset register and executor briefing letter, and we are pleased to assist in creating and reviewing these as part of our ongoing client relationship.

This guide is for general information only. The succession of assets in multiple jurisdictions requires specialist legal advice in each country where significant assets are held. Estate planning documents should be reviewed regularly, as laws change and personal circumstances evolve.