The 4 inheritance architectures
2-of-3 multisig: you, your spouse/heir, your lawyer's escrow service. Sealed instructions with executor pointing to seed locations. No single point of failure; no court can freeze access.
Service provider holds one of three keys. Annual fee $250-2,400/yr. They actively guide your heirs through recovery. AnchorWatch + Onramp add insurance.
SG/HK/UAE-based trust holds keys with court-recognised structure. Sygnum, Hex Trust, Coinhako Trust, AnchorWatch, Onramp. Better for estates >$500K and cross-border heirs.
For UHNW: a Singapore/HK/UAE family office holds BTC via licensed custodian + multisig + trust + insurance. Compliant for estates >$10M with complex Asian-jurisdictional heirs.
Sharia-compliant trust (Hex Trust Islamic, Wahed Trust, Sygnum Islamic Finance) holds and distributes per Faraid shares. Used by Gulf, Malaysian, Indonesian Muslim families.
Single hardware wallet + sealed envelope to executor with PIN + seed location. Cheap, simple, but high single-point-of-failure risk. Acceptable only for small holdings or as Tier 0 starting point.
Provider comparison (Asian access, May 2026)
| Provider | HQ | Asian clients accepted | Pricing | Insurance | Best for |
|---|---|---|---|---|---|
| Casa | 🇺🇸 US | Most Asia (SG, HK, JP, KR, AE, IN) | $10-250/mo by tier | $0; key replacement | 2-of-3 / 3-of-5 retail |
| Unchained Capital | 🇺🇸 US | Accept many Asian residents | $250-2,400/yr | via partners | HNW + business; loans |
| AnchorWatch | 🇺🇸 US | Most Asia | ~1.5% of value/yr | Lloyd's of London $25M+/client | Insured multisig |
| Onramp | 🇺🇸 US | Most Asia (depends on KYC) | Fixed + AUM tier | via partner custody | Tiered multisig + estate |
| Hex Trust | 🇭🇰 HK / 🇦🇪 UAE | Asia-native | ~0.5-1% AUM | Lloyd's | Institutional + Islamic finance |
| Sygnum Singapore | 🇸🇬 SG | Asia-native | Private banking fees | Bank-grade | UHNW + Islamic finance arm |
| Coinhako Trust | 🇸🇬 SG | Asia-native | Retail-friendly + custodial | via insurer | SG retail + trust accounts |
| DBS Digital Custody | 🇸🇬 SG | Accredited Asia | Bank fees | Bank-grade | Accredited-investor estates |
| Komainu | 🇯🇵 JP / 🇺🇸 US | Asia institutional | Institutional | via partners | JP-licensed institutional estates |
| Zodia Custody | 🇦🇪 UAE / 🇭🇰 HK | Asia institutional | Institutional | $425M coverage | UHNW + corporate estates |
| Wahed Trust | 🇦🇪 UAE | GCC + Asia Muslim | Custom | via partners | Sharia-compliant estates |
Step-by-step: 2-of-3 multisig with lawyer (most-used setup)
What you need
- 3 separate hardware wallets (one each for you, your spouse/heir, your lawyer's escrow). Recommended: Ledger Nano S Plus, Trezor Safe 7, Coldcard Mk4 / Q. Mix brands to reduce supply-chain risk.
- Sparrow Wallet (free) + Specter Desktop on a non-internet computer for setup
- A Bitcoin-aware lawyer (we maintain a list at community page)
- 2-4 hours initial setup; annual recovery test
- Generate 3 seed phrases on 3 separate hardware wallets. Each device generates its own 24-word seed offline. Verify each seed via the device screen — never via computer screen.
- Capture xpubs (public keys) from each device. Combine into a Sparrow multisig descriptor (2-of-3). Save the descriptor + each xpub as backup.
- Distribute hardware wallets geographically: Key 1 home safe, Key 2 trusted family member's home, Key 3 lawyer's escrow box. Never store two keys at one address.
- Store seed backups separately: each seed phrase on a fire/water/EMP-resistant metal plate (Cryptosteel, Coinplate, etc.). Keep separate from the hardware wallet that generated it.
- Sign a sealed-envelope SOP for your executor: where each key is located, how to contact the lawyer's escrow service, who has authority to coordinate. Never include the seeds themselves.
- Test recovery annually with a small (10K sat) test transaction. Confirm 2 of 3 keys can sign and broadcast successfully.
- Document tax basis for each major BTC acquisition. Make accessible to heirs. Helps avoid double-taxation surprises during estate transfer.
⚠️ Test recovery yearly. Not once at setup.
Hardware wallets fail. Lawyers retire. Family members move. Service providers change processes. An untested recovery plan is a fairy tale. Once a year, do a small recovery with 2-of-3 keys to verify the whole chain still works. Document who-was-in-the-room. Fix any breakage immediately.
Country-by-country legal landscape
🇸🇬 Singapore
Strong trust law (Trustees Act). Wills enforceable; probate routine. Trust companies can hold Bitcoin (Sygnum, Coinhako Trust, family-office structures). Inheritance tax: 0% on most assets. Best for cross-border Asian estates.
🇭🇰 Hong Kong
Hong Kong trust regime well-established. Bitcoin estate handling via SFC-licensed custodians (HashKey, OSL, Hex Trust). No estate duty (abolished 2006). Excellent for Greater China heirs.
🇯🇵 Japan
Strict probate (compulsory share rules). Inheritance tax up to 55%. Trust companies (Komainu via Nomura, SBI Trust) can hold Bitcoin. Significant tax planning required for >¥100M estates.
🇮🇳 India
No inheritance tax currently. 30% income tax on disposal applies regardless of inheritance receipt. Trust under Indian Trusts Act 1882 can hold BTC; some banks reluctant. Plan ahead for VDA tax structuring.
🇦🇪 UAE
Sharia law applies to Muslim residents by default. UAE residents can opt for non-Muslim wills via DIFC Wills Service or ADGM Courts. VARA-licensed custodians (Zodia, Hex Trust) integrate with estate planning. 0% inheritance tax.
🌍 Sharia inheritance specifics
Under Faraid, fixed shares to specific heirs (spouse, children, parents). Bitcoin treated as halal wealth in current scholarly consensus. Trusts must comply with prohibition on excessive uncertainty (gharar) and interest (riba). Use a Sharia-board-certified provider (Hex Trust, Wahed, Sygnum Islamic) to ensure compliant distribution. 1/3 of estate can be freely willed beyond Faraid shares.
Mistakes Asian families repeatedly make
Wills become public during probate. Anyone in the court — clerks, opposing parties, journalists — sees the seed. Lost minimum 1,000 BTC in 2024 from this single mistake. Use multisig + sealed instructions instead.
Banks routinely freeze a deceased person's box for 12-18 months during probate. If your only seed copy is in the box, your heirs cannot transact. Distribute keys across separate jurisdictions and custodians.
Most Asian lawyers cannot legally hold a seed phrase as part of normal practice. Use a service whose business model is exactly this (Casa, Unchained, AnchorWatch, Onramp) with appropriate legal structure for your jurisdiction.
SSS only adds security if shares are geographically and legally separated. Two SSS shares in the same house is one share — fire/burglary takes both.
Hardware wallets become obsolete, lawyers retire, services change processes. Untested recovery procedures break silently. Run a 10K-sat recovery test every year.
If your heirs don't know what Bitcoin is, they won't ask the right questions during probate. Brief them annually on what they're inheriting, where to look, and who to call.
FAQ
What happens if I die without an inheritance plan?
If keys are in self-custody and your heirs don't know where they are, the coins are lost forever. If the bank can identify exchange balances, they get transferred to heirs per probate (subject to capital-gains tax basis reset rules per jurisdiction). The asymmetry is brutal: a $1M BTC estate routinely becomes $0 to heirs simply because the plan didn't exist.
Should I include my Bitcoin in my will?
Yes — reference its existence and instructions to find it, but never include the seeds. A typical Bitcoin will clause says: "My Bitcoin assets are held in a 2-of-3 multisig managed by [Casa / Unchained / your lawyer's escrow]. My executor should contact [name + URL] for recovery procedure. Distribution per the schedule attached to the sealed envelope held by [lawyer's office]."
Can I leave Bitcoin to charity in Asia?
Yes. Open Sats, Human Rights Foundation, and many Asian charities accept BTC directly. Use a charitable trust structure (SG/HK trusts) for tax efficiency. Document the donation pathway in your sealed instructions so the executor doesn't have to figure it out.
Are there Sharia-compliant Bitcoin estate services?
Yes: Hex Trust Islamic, Wahed Trust, Sygnum Islamic Finance, ADIB digital asset partners. They combine multisig custody with Sharia-board-approved trust structures that handle Faraid distribution. Available across the Gulf and increasingly in Malaysia + Indonesia.
What's the minimum I should think about inheritance?
If your Bitcoin holdings exceed 6 months of your household's expenses, you should have at least a sealed-envelope SOP. If they exceed 2 years of expenses, multisig with a service provider. If they exceed $500K, full trust structure with licensed custodian. The cost of planning is dramatically lower than the cost of loss.
Can my heirs avoid Indian / Japanese / Korean estate taxes via Singapore custody?
Custody location doesn't determine taxation — your country of tax residence at death does. Singapore custody can simplify operational handover but doesn't escape Japanese inheritance tax for a JP-resident decedent. Work with a cross-border estate planner experienced in Asian + Western jurisdictions for the right structure.