Date: October 22, 2026
When a parent dies leaving a bank account in China, the same procedure applies whether the parent died in China or in the U.S. — what matters is the Chinese account. A U.S. probate order alone won’t release it.
U.S.-based heirs generally need three documents:
- Death certificate notarization — if the parent died in the U.S., the U.S. death certificate needs U.S. notarization + Apostille (accepted in China since November 2023) + Chinese translation before a Chinese notary can use it.
- Kinship proof — notarized proof of the family relationship (e.g., birth certificate, household registration). U.S.-issued proof needs the same Apostille + translation.
- Certificate of succession (继承权公证书) — issued by a Chinese notary office after reviewing the above, confirming who inherits.
Which law decides who inherits? For a bank deposit, Chinese conflicts rules (Law on the Application of Laws to Foreign-Related Civil Relations, Art. 31) look to the law of the parent’s habitual residence at death — so if the parent lived in the U.S., U.S. state law may decide the heirs. Either way, the Chinese bank may require the same notary certificate.
If the parent also owned assets in Ohio, those are handled separately under Ohio law — intestate succession under ORC 2105.06 if there was no will.
This article is general information, not legal advice. Questions? Contact Lei Jiang Law Firm at (440) 835-2271.