Checklist: managing contactless assets and historical risk
- Put in place procedures to identify relationships whose holders no longer make contact and document the steps taken to trace them.
- Comply with the statutory and professional obligations of search, reporting and publication that apply to contactless and dormant assets.
- Retain the archives needed to respond to requests from entitled persons, including for old relationships.
- Handle requests from heirs with diligence and keep the requirements of proof proportionate to the circumstances, in particular where the usual documents cannot be produced.
- Assess the reputational risks arising from the institution’s history and from its past relationships with controversial regimes or clients.
- Monitor the development of foreign court proceedings and inquiries that may concern the institution or its predecessors.
For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.