Where is the key to the vault?

Reflections on the hidden obstacles we unknowingly leave to our heirs

My professional insights · Lyudmil Karaulanov · 13 min read

Published: 1 October 2026 · Version 1.0

When a loved one dies, tracing accounts and documents can hardly be the family's first concern. Yet this is precisely when it becomes apparent how much only that person knew. The bank's name, the conversation with the intermediary and the folder containing proof of ownership may be missing from the family's shared memory.

This difficulty deserves consideration without reproaching the heirs. Entitlement to property and the ability to find and receive it are separate tasks. When both are left for the same difficult period, every uncertainty can make the next step still harder.

A story without an ending

In one cross-border case, bank funds remained in the account of a person who had died abroad. In the meantime, the bank holding the account had ceased operating in the country, and another institution had taken over servicing its customers. The deceased's brother began looking for the funds more than a decade after the account holder's death. According to the available documents, the heirs had been the brother and their mother. After the mother's death, her rights passed to her son.

The bank had to establish not only that the account holder had died, but also who was entitled to act in his place. It requested documents identifying the heirs and the applicable law, evidence of death and properly authenticated foreign documents. The account itself also had to be identified: an old customer's account at a bank that no longer existed.

While all this was continuing, the brother, who had begun the search, also died. The next heir now had to prove not only their own status, but the entire path by which the rights had reached them.

An ordinary bank claim thus became a chain of inheritances, each with its own facts, documents and applicable law. The story still has no ending.

Rights pass on. Information does not always follow.

Inheritance is not a single fact proved by one certificate. Successive deaths give rise to separate succession relationships. For each, it must be established who died, when and where, which law governs the succession, who the heirs are and which rights passed to the next person.

The chain has another, less familiar feature. When an heir dies before accepting the inheritance due to them, the right to accept does not disappear. It passes to their own heirs. The next generation thus inherits not only property, but also the unfinished decisions of the previous one. Each link may be governed by a different law, require different documents and be situated in a different country. The longer the chain, the harder it is to prove that every link is sound.

The European Certificate of Succession can make proof easier in cross-border cases, but it is not a universal document for every inheritance. The European Union regulation creating it applies to the succession of persons who died on or after 17 August 2015. For an earlier death, another means of proof must be found. The question is assessed separately for each subsequent death.

More important still is what the certificate does not prove. The regulation itself specifies that its evidentiary effect does not extend to matters it does not govern, such as whether a particular asset belonged to the deceased. In other words, the document says who the heir is, but not what has been inherited. This boundary is not a technical detail. It shows that proving entitlement and finding the property are two separate tasks, each requiring preparation of its own.

Foreign documents bring their own burden. Between European Union countries, certificates of birth, death and kinship no longer require an apostille and may be accompanied by multilingual standard forms. This simplifies form, but not substance: the foreign document continues to reflect the law and concepts of the issuing country. Outside the Union, these simplifications do not apply, and each link in the chain may require separate legalisation and translation.

A will expresses wishes. An asset map shows what exists and where it is. Succession documents prove who acquires rights. A power of attorney or another legal basis determines who can act on a particular person's behalf. These are different parts of one system. When one is missing, the others cannot replace it.

Why the institution is cautious

Relatives' impatience is understandable when yet another document is requested. The bank, for its part, is obliged to establish whom it can pay and how that entitlement is proved. It helps to identify exactly which link is missing rather than experience every request as a general refusal to cooperate.

The European legislature has therefore provided protection specifically for it. Anyone paying or handing over inherited property to the person entitled under the certificate is protected when acting in good faith on the basis of the certified information. The bank's caution is a reasonable response to uncertainty. The problem is not the institution. It is the absence of an orderly chain of documents on which it can rely.

Where is the account?

In Bulgaria, heirs have a tool that many do not know about. The Register of Bank Accounts and Safe Deposit Boxes, maintained by the Bulgarian National Bank, contains information about account holders, authorised persons, account numbers, types and currencies, opening and closing dates, and attachment orders. It has operated since 1 January 2017 and is often used by heirs, who need a certificate of heirs to request a search.

The register, however, answers "where", not "who". It shows that an account exists, but does not prove who is entitled to it. And it covers only banks in Bulgaria. It does not help in a cross-border case such as the one described.

This reveals a telling mismatch. In recent years, European countries have built centralised bank account registers for use by anti-money-laundering authorities, rather than heirs. In practice, the system is arranged so that discovering an offender's account is easier than an heir discovering their parent's account in a neighbouring country.

Time is not neutral

A search is easily postponed when it seems complicated and there is no clear first move. Meanwhile, those who know the history may become unavailable, institutions may change and documents may become scattered. In my view, it is therefore better to start with what is available and organise the gaps along the way.

The Swiss experience is revealing. Since 2015, Swiss law has required assets for which there has been no customer contact for at least 60 years to be transferred to the state. Before that happens, account holders' names are published online where the value exceeds 500 francs or is unknown. The first published list contained just over 2,600 names linked to assets of around 44 million francs, as well as some 80 safe deposit boxes.

The outcome is the most telling part. According to the Swiss Bankers Association, publication led to an entitled person being found for only around one in twenty of the assets that had remained without contact for decades. If no one makes a claim within the deadline, the assets pass to the state and claims are extinguished. Specialists in tracing heirs note that many of these records lack even the customer's date of birth or nationality.

Delay can make tracing and proof more difficult: memories fade, documents become scattered and new succession relationships sometimes arise. Legal consequences and deadlines must be checked for the particular asset and country. The practical reason to begin in time is simple: a person or document available today may no longer be available tomorrow.

When the person entitled cannot act alone

Continuity becomes more complicated when the heir is absent, is a minor or cannot personally take the necessary steps. This does not mean they lose their entitlement. It means an appropriate mechanism is needed for representation, protection of their interests and contact with institutions.

A gap can easily open here. Relatives may know that someone is entitled to the asset, but not who can speak on their behalf. The institution may be unable to share information with a person who has not yet proved their authority. And the person who could explain what has already been started may no longer be available.

An heir's difficulty in taking over the process must therefore not become a reason for others to bypass their rights. It signals that the system needs to provide for information and representation to reach them lawfully and in an understandable way.

Memory is not a mechanism for continuity

The person who knows the history can be an invaluable help. But all the preparation cannot remain in their memory. They too may be absent or unaware of the latest change. Accessible instructions and documents are needed to enable another competent person to continue the work.

Professional memory, however, is not authority. As a rule, a power of attorney terminates on the principal's death and does not in itself authorise representation of the new heir. A lawyer may preserve important context, but needs a legal basis to continue acting and share information with the person now entitled to receive it.

The law offers ways to fill this gap in advance. The testator can appoint an executor who, within the limits permitted by law, can complete what has been started and connect the heirs with the institutions. A client can also leave clear instructions about who should receive the file on their affairs and under what conditions. This is not a formality. It is the difference between a process that continues and one that starts from scratch with each new generation.

The trusted professional's role is not to replace the heir, but to prevent completed work from being lost. The same question arises for assets held in specially established structures: a structure may determine who manages and who benefits, but does not remove the need for clear rules, documents and continuity.

Where is the point of instability?

What this concept means →

It arises when an heir has an entitlement but insufficient information or evidence to exercise it. With successive inheritances and different countries, the gaps can accumulate.

Care during one's lifetime involves more than expressing wishes. It includes an asset map, a trail to the documents and clarity about whom loved ones can contact. What you have created for them then has a better chance of actually reaching them.

This material is of a general analytical nature and does not constitute individual legal, tax, financial or investment advice.