If you are an African professional living in London, Toronto, Houston, or anywhere else in the diaspora, there is a good chance your financial life spans two or three countries at once. A pension building up at your UK employer. A savings account and a mortgage in your city of residence. And back home: a plot of land your parents helped you buy, an apartment you rent out in Lagos or Accra, maybe a stake in a family business. This is completely normal, and it is also one of the most complicated inheritance situations there is.
The typical diaspora asset picture
Diaspora families rarely have a single, tidy estate. A common pattern looks something like this: property in Lagos purchased with UK-earned income, a pension or workplace investment account in the country of residence, a joint account back home that a parent or sibling also has access to, and increasingly, crypto holdings that exist independently of any single country's banking system. Each of these sits under a different legal system, with different rules about who inherits what and how.
Why cross-border inheritance is genuinely hard
The core problem is that inheritance law is almost always national, not international. The UK applies its own succession rules to UK-situated assets. Nigeria, Ghana, or Kenya apply their own rules, which may be a mix of statutory, customary, or religious law, to assets located there. A will written and valid in London is not automatically recognised or straightforward to execute for property in Lagos, and vice versa. Families are often surprised to learn that they may need separate legal processes, sometimes with separate lawyers, in each country where assets are held.
Different probate systems, different timelines
Even the basic process of proving who is entitled to inherit, called probate in common law countries, works differently everywhere. The UK Probate Registry issues a Grant of Probate or Letters of Administration based on English law. Nigerian State High Courts do the same under Nigerian law, but the documentation, waiting times, and even the courts' expectations around customary or Islamic law considerations can be very different. A diaspora family often has to run two or three of these processes in parallel, in different countries, sometimes years apart as each jurisdiction's court moves at its own pace.
Will a foreign will even be recognised?
This is one of the most common points of confusion. Many countries will recognise a foreign will as valid evidence of intent, but still require it to go through a local, sometimes called "resealing," process before it has legal effect over locally situated assets. This is rarely automatic, and families who assume a UK or US will alone is sufficient to unlock a Lagos property often discover otherwise, at exactly the wrong moment.
Practical steps for diaspora families
- Keep a single written record of every asset you hold, in every country, with the country and institution clearly noted.
- Consider whether you need separate wills for separate jurisdictions, and get advice on how they interact rather than assuming one covers everything.
- Make sure your next of kin, wherever they live, know who to contact in each country, not just at home.
- Do not assume family members back home know about assets you hold abroad, or that family abroad know about assets you hold at home. Diaspora families are often surprised by both.
How Remayn helps diaspora families specifically
Remayn's Global plan was built exactly for this situation. You can register assets across Nigeria, the UK, the US, or any combination of countries in one encrypted vault, and designate next of kin anywhere in the world. When our verification protocol confirms extended inactivity, your next of kin receives a single, complete guide covering every country and every asset you registered, with general guidance on the legal process relevant to each location, so they are not discovering a Lagos property or a UK pension for the first time while also trying to navigate an unfamiliar legal system on their own.
You built a life across borders. Your family's ability to access what you built should not depend on which country's paperwork they happen to find first.
