When a relative dies, the accounts they held in Israel stop being accessible. For heirs living abroad, that freeze quickly turns into a lasting deadlock: the Israeli bank applies its own requirements, and neither a foreign certificate of heirship nor a European Certificate of Succession is enough to satisfy them. Here is what the bank actually expects, and the point at which appointing an estate administrator becomes the only way forward.
I. Why the bank freezes the account as soon as it learns of the death
As soon as an Israeli institution is notified that its client has died, it suspends the account: withdrawals, transfers and payment instruments stop working. This freeze is neither a penalty nor administrative slowness — the bank has no authority to decide who inherits, and it would be exposing itself to liability by releasing funds to someone with no entitlement to them.
Two misunderstandings come up again and again:
- Banking powers of attorney granted during the account holder’s lifetime do not survive their death. A mandate ends when the principal dies: a child who held signing authority on a parent’s account loses that access upon death, even if the bank has not yet reacted.
- A joint account and its survivorship clause do not settle everything. A clause providing that the survivor keeps the account governs the relationship with the bank, but it does not on its own determine who owns the funds as between the heirs — a recurring source of litigation.
II. What the Israeli bank requires before releasing anything
The central document is the decision identifying the heirs:
- the inheritance order — Tsav Yerusha (צו ירושה) where there is no will;
- the probate order — Tsav Kiyum Tsavaa (צו קיום צוואה) where there is one.
That decision is issued by the Registrar of Inheritance Affairs — Rasham LeInyanei Yerusha (רשם לענייני ירושה), or by the Family Court where the file is contested or where a foreign element requires it. In Israel it is the lawyer who files the petition and runs the procedure. In practice, each institution adds its own requirements on top:
- identification of every heir, with documents translated and bearing an apostille where they come from a foreign authority;
- a notarial power of attorney — Yipouy Koach Notarioni (ייפוי כוח נוטריוני) where an heir cannot travel to Israel;
- compliance and tax-residence documentation, as banks systematically examine the position of non-resident heirs before authorising any transfer abroad.
Requirements vary appreciably from one bank to another, sometimes from one branch to another: it is worth having the list checked before commissioning translations and legalisations, whose cost and lead times add up quickly.
III. When release hits a wall: the role of the Menahel Izavon
An inheritance order identifies the heirs; it does not make the account work. Where several heirs must act together and one of them holds back, nothing moves. This is where the estate administrator — Menahel Izavon (מנהל עיזבון) comes in, an appointment sought from the Registrar or from the Family Court. The situations that most often justify it:
- heirs who disagree, or one of whom refuses to sign the bank’s forms;
- the presence of minor or protected heirs, which brings in the Administrator General — Apotropos HaKlali (האפוטרופוס הכללי);
- debts and creditors to be satisfied before any distribution;
- an heir who cannot be found or contacted;
- an estate scattered across several accounts, securities portfolios or safe-deposit boxes.
Appointed on a temporary or permanent basis, the administrator becomes the bank’s single counterpart: they obtain access to statements, gather the assets, draw up the estate inventory — Pirtat HaIzavon (פרטת העיזבון) and account for their management. Their powers are supervised: the appointing authority may require a security or bond (ערובה), and certain significant acts call for prior authorisation. That supervision is precisely what reassures the bank, which then deals with someone whose mandate and limits are set out in a formal decision.
IV. The accounts nobody knew existed
Many cross-border estates stumble on a more basic difficulty: the heirs do not know where the deceased held their assets. Israel’s Ministry of Finance runs a public search service, Har HaKesef (הר הכסק), which helps locate dormant accounts and forgotten financial assets. The estate administrator, for their part, has standing to approach institutions directly and reconstruct the estate — including a safe-deposit box whose key has gone missing. Without an appointment, nobody has the standing to ask the question.
V. Two different logics on either side of the border
The comparison explains most of the misunderstandings:
- The pivot is not the same. In France, a civil-law notary draws up the certificate of heirship and the bank releases the funds on that basis; below a threshold set by regulation, a declaration signed by the heirs can suffice. Israel has no equivalent of a French notary settling an estate: the procedure takes place before the Registrar or the Family Court, conducted by the lawyer. The Israeli notary — Notarion (נוטריון) is a specially licensed lawyer, competent for powers of attorney, certifications and translations, not for administering the estate.
- European instruments stop at the Union’s borders. EU Regulation 650/2012 and the European Certificate of Succession do not bind Israel: produced at an Israeli bank counter, a European certificate has no effect.
- French mandates have no direct counterpart. The posthumous mandate (article 812 of the Civil Code), the contractual mandate agreed between heirs (article 813) and the court-appointed estate agent (article 813-1): none amounts, in itself, to the appointment of a Menahel Izavon in Israel — and the reverse is equally true.
- Tax does not compare either. Israel levies no inheritance tax; where the estate includes real property, however, a later sale raises the question of capital gains tax on real estate — Mas Shevah (מס שבח), better examined before selling than after.
Conclusion – Why work with a lawyer on estate administration?
Releasing an Israeli account from abroad is not a matter of filling in a form: it means aligning an Israeli decision, foreign civil-status records, certified translations and one bank’s particular requirements. Every missing link sends you back to the start. ABITBOL & ASSOCIÉS brings together lawyers admitted to both the Israeli Bar and the Paris Bar, as well as an Israeli notary: the petition before the Registrar, the appointment of an administrator, the powers of attorney and the certified translations are handled in a single chain, with no break between the two legal systems.
With this in mind, ABITBOL & ASSOCIES, drawing on its expertise in Israeli and international succession law, supports its clients at every stage of releasing an estate’s bank assets in Israel and of estate administration. Our lawyers make sure your interests are protected and that each step is taken in complete security.
13 Av Hubert Germain – Paris 16ᵉ
Tel: + 33 (0)1 78 90 03 73
Fax: + 33 (0)1 77 74 63 99
13 rue Shimon ben Shetah, 9414713, Jérusalem
Tel: + 972 (0)2 595 63 45
Fax: + 972 (0)2 591 63 26
Contact us
For any question concerning your personal situation, please leave us a message:
Publications similaires :
The Estate Administrator in Israel: When and How to Have One Appointed
Successions Israël-France: la nouvelle réglementation européenne en matière de succession internationale
Successions Israël-France: la nouvelle réglementation européenne en matière de succession internationale
L’expertise du Cabinet ABITBOL & ASSOCIES en Droit International
Brochure PDF
