Asset-Protection Trusts by Jurisdiction
How each jurisdiction's asset-protection trust statute is written — the authorizing act, the lookback window, who carries the burden and to what standard, and how foreign judgments are treated — for international jurisdictions and US states side by side.
Short answer
Asset-protection trust law differs by jurisdiction on a small number of concrete statutory terms: which act authorizes the trust, how long a creditor has to attack a transfer, which party carries the burden of proof and to what standard, whether a bond is required, and whether a foreign judgment is recognized at all. This matrix records those terms for each jurisdiction from that jurisdiction's own official source, with the cells that were not confirmed left visibly unconfirmed.
The matrix
| State | Statute Name | Statute Year | Fraudulent Transfer Lookback Years | Burden Of Proof | Standard Of Proof | Foreign Judgment Recognition | Creditor Bond Requirement | Duress Clause | Notable Case Law | Regime Type |
|---|---|---|---|---|---|---|---|---|---|---|
| Cook Islandschecked 2026-09-13 | International Trusts Act 1984, ss.13A-13K (the asset-protection provisions), inserted by the International Trusts Amendment Act 1989 and refined by the International Trusts Amendment (No. 2) Act 1989, No. 31. | 1984 (principal Act); 1989 (ss.13A-13K asset-protection provisions, refined by the 'No. 2' amendment, 1989 No. 31). | 2 years from the date the creditor's cause of action accrued (s.13B(3)); if the settlement/disposition occurs within that 2-year window, the creditor must also commence proceedings within 1 year of the settlement or disposition (s.13B(3)(b)). Confirmed unchanged by the 2004 (No. 7) and 2013 (No. 15) amendments, which touch only registration/privacy/records provisions. | On the challenging creditor (s.13B(7): 'the onus of proof of the settlor's intent to defraud the creditor lies on the creditor'). | Beyond reasonable doubt (s.13B(1)); reaffirmed procedurally at s.13K(3), which bars the court from even hearing an action unless satisfied beyond reasonable doubt that it is not precluded. | re-litigate. A foreign judgment against an international trust or interested party is not entertained, recognised or enforced by a Cook Islands court to the extent it is based on a law inconsistent with the Act (or the Trustee Companies Act), or relates to a matter governed by Cook Islands law (s.13D). | none -- the International Trusts Act 1984, as amended through 2013, contains no creditor bond/deposit-before-suit requirement (unlike the Nevis International Exempt Trust Ordinance s.61). | none | FTC v. Affordable Media, LLC, 179 F.3d 1228 (9th Cir. 1999) -- settlors of a Cook Islands international trust held in civil contempt for refusing to repatriate assets; the 'impossibility of compliance' defense was rejected because the settlors retained practical control. The canonical case testing the regime (also the basis of the counsel memo's D3 offshore-AP bound). | creditor-defeat |
| St. Kitts & Nevis — Nevischecked 2026-09-13 | Nevis International Exempt Trust Ordinance, Cap. 7.03 (N) (Laws of Saint Christopher and Nevis). | 1989 (Ordinance 1 of 1989); in force 1 May 1994. | 1 year from the date the creditor's cause of action accrued (s.26(3), as substituted by Ordinance 2 of 2015 -- reduced from an earlier 2-year rule). | On the challenging creditor (s.26(7): 'the burden of proof regarding the settlor's intent to defraud the creditor is on ... the creditor'). | Beyond reasonable doubt (s.26(1)). | re-litigate. A foreign judgment against an international trust, settlor, trustee, protector, beneficiary, or related person/property is not enforced or recognised by the Nevis court if based on a law inconsistent with the Ordinance, or if it relates to a matter governed by Saint Christopher and Nevis law (s.30). | EC$270,000.00 (Eastern Caribbean Dollars, per the Ordinance's own s.2 interpretation: '"Dollars" or "$" means Eastern Caribbean Dollars unless expressly stated otherwise' -- approximately US$100,000 at the standing EC$/US$ peg), deposited with the Permanent Secretary, Ministry of Finance, from a Nevis financial institution, before any action or proceeding against trust property (s.61, as amended by Ordinances 4 of 2009 and 2 of 2015). | Yes. Where a person is granted a power under a trust to act on the demand or direction of another, that person, to the extent they would incur no personal liability, must recognise and act only upon a demand or direction given by a person acting of their own free will -- disregarding one compelled by duress, including compulsion by a foreign court order (s.16). | Not yet researched | creditor-defeat |
| St. Kitts & Nevis — Federationchecked 2026-09-13 | No St. Kitts/Federation-level self-settled asset-protection trust or foundation statute exists (distinct from the Nevis International Exempt Trust Ordinance, which is Nevis-specific under the Federation's constitutional structure). The Federation-wide Trusts Act, Cap. 5.19 (Act 23 of 1996, in force 2 April 1997), governs ordinary trust administration but contains no asset-protection/creditor-defeat provisions. | 1996/1997 (Act 23 of 1996, in force 2 April 1997); current consolidation as at 31 December 2020; no separate AP-specific statute exists at any date. | No fixed number of years running from the transfer date. SKN's Limitation Act, Cap. 5.09, s.25 applies a discovery-based rule to any action founded on fraud: the period of limitation shall not begin to run until the plaintiff has discovered the fraud, or could with reasonable diligence have discovered it (subject to a bona fide purchaser-for-value proviso). The general 6-year period for simple contract/tort actions (s.4(1)) supplies the base period once the clock starts at discovery, not at the transfer itself. | Not yet researched | No heightened standard of proof is stated anywhere in Trusts Act Cap. 5.19; no AP-specific vehicle or provision exists at the Federation level for a heightened standard to attach to. | treaty-only. Two SKN Federation statutes govern, both operating as closed designated-country/Order-in-Council registration schemes, not general recognition: (1) Foreign Judgments (Reciprocal Enforcement) Act, Cap. 3.13, s.3(1)-(2) -- the Governor-General may by Order extend Part II's registration mechanism to a specific foreign country on a finding of reciprocity; only Victoria and South Australia are so designated. (2) Reciprocal Enforcement of Judgments Act, Cap. 5.14, s.6(1) -- extends the UK-judgment registration mechanism to other Commonwealth territories only by Order; designated territories are Bahamas, Barbados, Bermuda/British Honduras/Trinidad & Tobago, British Guiana/St Lucia/St Vincent/Grenada, Jamaica, New South Wales, and Nigeria. Neither Act designates the United States or any AP-trust-relevant offshore jurisdiction. | none -- Trusts Act Cap. 5.19 reviewed in full, no creditor bond/deposit-before-suit requirement found. | none -- Trusts Act Cap. 5.19 reviewed in full, no duress/flight clause found. | Not yet researched | none |
| Liechtensteinchecked 2026-09-13 | Foundation (Stiftung) vehicle: Personen- und Gesellschaftsrecht (PGR) Art. 552 §§1-41 (structure confirmed directly from gesetze.li's own table of contents: §36 'Vollstreckungsrechtliche Bestimmungen' [enforcement-law provisions], §38 'Anfechtung' [challenge/avoidance] both exist within Art. 552's Foundation framework). Creditor-avoidance mechanism: Rechtssicherungs-Ordnung (RSO) of 9 February 1923, SR 283.0, 2. Abschnitt 'Anfechtungsordnung' Art. 64-75. | RSO enacted 1923 (LGBl. 1923 Nr. 8); PGR (Foundation provisions) enacted 1926, Art. 552 substantially revised 2008/2009 per secondary sources (not independently primary-confirmed this session). | Compound structure, RSO Art. 64-67 + 74: over-indebtedness ground (Art. 66) -- 1 year before enforcement authorization; general fraud-intent ground (Art. 67) -- no time limit on the act itself; outer limitation on bringing ANY avoidance claim (Art. 74(1)) -- 5 years from when the challengeable act was undertaken. | On the challenging creditor (Anfechtungsglaubiger) -- Art. 65(2): the burden of proof for the facts and circumstances establishing the avoidance claim lies with the challenging creditor. | No heightened standard is stated anywhere in RSO Art. 64-75; ordinary civil standard applies by default. | treaty-only -- Liechtenstein recognizes/enforces foreign civil judgments only under specific bilateral treaties: confirmed via gesetze.li itself, the Switzerland-Liechtenstein Convention of 25 April 1968 on recognition and enforcement of judicial decisions and arbitral awards in civil matters (in force 15 March 1970). An analogous Austria treaty (5 July 1973) is reported consistently across multiple secondary legal-practice sources but was not independently fetched/confirmed from a primary source this session. | none -- no bond or security-deposit requirement of a creditor found in RSO Art. 64-75 (full-text search for bond-equivalent terms: zero hits). | none -- no duress/flight clause exists in RSO Art. 64-75 (the only compulsion-root hits are 'Zwangsvollstreckung', i.e. ordinary compulsory enforcement, not a trustee-duress provision); PGR Art. 552's Foundation-specific §36/§38 text was not separately full-text-searched this session for a duress clause -- genuinely open on that narrower point. | Not yet researched | firewall |
| Cypruschecked 2026-09-13 | The International Trusts Laws 1992 to 2013 (69(I) of 1992, as amended by 20(I) of 2012 and 98(I) of 2013). | 1992 (principal Law 69(I)/1992); amended 2012 (20(I)/2012, the substantive AP-trust overhaul) and 2013 (98(I)/2013, last material amendment -- repealed s.15). | 2 years from the date the transfer/disposal of assets was made to the trust (s.3(3)) -- measured from the transfer itself, not accrual of the creditor's cause of action. | On the challenging creditor (s.3(2): the onus of proof of such intent lies on his creditors). | No heightened standard is stated anywhere in the Law; ordinary civil standard applies by default (contrast Cook Islands/Nevis's express beyond-reasonable-doubt standard). | re-litigate | none -- no bond or security-deposit requirement of a challenging creditor found anywhere in the Law. | none -- no duress/flight clause protecting a trustee against foreign-court compulsion exists (contrast Nevis s.16). | Not yet researched | firewall |
| Jerseychecked 2026-09-13 | Trusts (Jersey) Law 1984, Official Consolidated Version. | 1984 (Law enacted); current consolidated text as amended through the version shown 'from 20 March 2026 to Current'. | Not yet researched | Not yet researched | Not yet researched | re-litigate | none -- full-text search of the Law found zero occurrences of 'bond'; no creditor bond/deposit-before-suit requirement exists. | none -- Art. 11(2)(b)(i) uses 'duress' only as a ground to invalidate a trust's CREATION (with fraud, mistake, undue influence, misrepresentation, breach of fiduciary duty) -- a distinct concept from a protective fiduciary-duress clause shielding a trustee from foreign-court compulsion (contrast Nevis NIETO s.16). No protective clause of that kind exists. | Kea Investments Limited v Watson and Ors [2021] JRC 009 (Royal Court of Jersey, 19 January 2021). Held, on an application to confirm an arrêt over a judgment debtor's interest as discretionary beneficiary of three Jersey trusts, that the interests constitute movable property under Article 10(10) of the Trusts Law, but are not assignable or transmissible under the trust deeds' own terms, so the court would not confirm the arrêt over them: a discretionary beneficiary's interest, where the trust deed makes it non-assignable, is not reachable by a creditor's arrêt even though it is movable property in the abstract. | firewall |
| Switzerlandchecked 2026-09-13 | No domestic self-settled/asset-protection trust or foundation statute. Switzerland's own civil law (ZGB) does not recognise the trust as an indigenous institution; it recognises only foreign-law trusts under the Federal Act on Private International Law (PILA/IPRG), Chapter 9a. | 2007 (Chapter 9a in force 1 July 2007, implementing Switzerland's 2007 ratification of the 1985 Hague Convention on the Law Applicable to Trusts and on their Recognition); no domestic APT vehicle exists at any date. | No trust-specific rule. General creditor-avoidance regime (Debt Enforcement and Bankruptcy Act, SchKG): 1 year before distraint/bankruptcy for gratuitous dispositions (Art. 286) and for over-indebtedness transfers (Art. 287); 5 years before distraint/bankruptcy for transfers made with intent to prejudice creditors (Art. 288); the avoidance action itself is separately time-barred 3 years from the unpaid-debt certificate or bankruptcy declaration (Art. 292). | No trust-specific rule. Under the general SchKG avoidance regime, the creditor bears the burden by default; it shifts to a close associate/relative of the debtor to disprove a disproportionate consideration (Art. 286(3), gift-adjacent avoidance) and to disprove a recognisable intent to prejudice (Art. 288(2), wilful-act avoidance); for the separate over-indebtedness ground, the recipient bears the burden of proving lack of knowledge of the debtor's over-indebtedness (Art. 287(2)). | No heightened standard of proof is stated in SchKG Title Ten (Arts. 285-292) for an avoidance action; the ordinary Swiss civil standard applies by default in the absence of a heightened-standard provision. | Conditional direct recognition, not automatic re-litigation. Foreign decisions on trust-law matters are recognised in Switzerland if rendered by a court validly chosen under the trust deed, or in the state of the defendant's domicile/habitual residence, the trust's seat, or the state whose law governs the trust, or if recognised in the trust's seat state where the defendant was not domiciled in Switzerland (PILA Art. 149e). The GENERAL foreign-judgment regime (Arts. 25-29) similarly recognises an ordinary foreign money judgment directly, subject only to a Swiss-public-policy/proper-notice/no-parallel-proceeding filter -- with no review of the foreign decision on the merits (Art. 27(3)). NOTE: this is the pre-flagged Switzerland delta field (spike sec. 4) -- Switzerland's PILA-based conditional recognition does not map cleanly onto the recognized/re-litigate/treaty-only trichotomy built for offshore-firewall jurisdictions. | none -- no bond or security-deposit requirement of a creditor is found in SchKG Arts. 285-292 or PILA Arts. 25-28; structurally absent given the lack of a domestic self-settled trust vehicle to bring such an action against. | none -- no duress/flight clause exists; structurally inapplicable given the lack of a domestic trustee subject to foreign-court-compulsion duress under Swiss law (no indigenous self-settled trust vehicle). | Not yet researched | none |
| Monacochecked 2026-09-13 | Loi n. 214 du 27 fevrier 1936 portant revision de la loi n. 207 du 12 juillet 1935 sur les trusts (Monaco's trust-recognition statute), as amended (most recently by Loi n. 1.559 du 29 fevrier 2024). | 1936 (Loi n. 214, itself a revision of Loi n. 207 of 12 July 1935); most recently amended by Loi n. 1.559 du 29 fevrier 2024, effective 1 March 2024. | No Monaco-specific rule. Art. 5 provides that disputes over a trust's constitution, transfer, or functioning in Monaco are resolved by Monegasque courts applying the FOREIGN law chosen to govern the trust -- not Monaco domestic law -- expressly disapplying Monaco public policy (ordre public). Full-text review (Arts. 1-13-3, Titre II) found zero references to a limitation/prescription period for creditor challenges. | No Monaco-specific rule -- governed by the trust's chosen foreign proper law per Art. 5. Full-text review found zero references to a creditor burden-of-proof allocation. | No Monaco-specific rule -- governed by the trust's chosen foreign proper law per Art. 5. Full-text review found no heightened-standard language anywhere in Law 214. | recognized. A foreign judgment that has acquired res judicata status is recognized de plein droit (as of right) in Monaco, provided none of the Article 15 refusal grounds applies (lack of jurisdiction under Art.17's tests, due-process violation, manifest contrariety to Monégasque public policy, conflict with a Monaco judgment or earlier-recognized foreign judgment, or lis pendens in a Monaco court). Recognition itself requires no separate proceeding (Art.13); enforcement of an executory foreign judgment additionally requires a declaration of enforceability (exequatur) from the Tribunal de Première Instance (Art.14); Monaco courts never review the foreign judgment on the merits (Art.16, révision au fond barred). | none -- governed by the trust's chosen foreign proper law per Art. 5, not Monaco domestic law. Full-text review found no creditor bond/deposit-before-suit requirement. | none -- governed by the trust's chosen foreign proper law per Art. 5, not Monaco domestic law. Full-text review found no duress/flight clause. | Cour d'appel, 29 November 1994, Dame D. c/ Hoirie F. (IDBD 26327) -- holding that under Art. 2 of Law 214/1936, a testamentary trust not executed in authentic form must be declared null and void, with succession settled ab intestat. Addresses formal-validity requirements, not a creditor/asset-protection dispute specifically; no Monaco case law on a creditor challenge to trust property was located this session. | none |
| Italychecked 2026-09-13 | No indigenous trust institution. Italy recognizes foreign-law trusts under Legge 16 ottobre 1989, n. 364 (ratifying the Hague Convention on the Law Applicable to Trusts and their Recognition, 1 July 1985); a settlor's transfer of assets into such a trust is challengeable only under the Codice Civile's general fraudulent-conveyance action, azione revocatoria (R.D. 16 marzo 1942, n. 262, Arts. 2901-2904). | Legge 364/1989 enacted 16 October 1989, domestic force from 9 November 1989; the underlying Hague Convention entered into force for Italy 1 January 1992 (confirmed via HCCH's own status table: signature 1-VII-1985, ratification 21-II-1990, EIF 1-I-1992). Codice Civile Arts. 2901-2904 enacted 1942, in force since 19 April 1942, unamended to date. | 5 years from the date of the act (Art. 2903 c.c.: L'azione revocatoria si prescrive in cinque anni dalla data dell'atto). | On the challenging creditor -- Art. 2901 requires the creditor to show the debtor knew the act prejudiced the creditor's interests (or, for acts predating the credit, that it was fraudulently pre-arranged), and for onerous acts, that the third party was aware of the prejudice. | No heightened standard is stated anywhere in Arts. 2901-2904; ordinary civil standard applies by default. | recognized -- Legge 218/1995 (riforma del diritto internazionale privato) Art. 64: a foreign judgment is recognized in Italy without any further proceeding when the rendering court had jurisdiction under Italian principles, the defendant received proper notice and defense rights, the parties appeared or default was properly declared, and the judgment is final under the law of its own forum. | none -- Arts. 2901-2904 reviewed in full, no bond or security-deposit requirement of a creditor. | none -- Arts. 2901-2904 reviewed in full, no duress/flight clause; structurally inapplicable given no indigenous trustee subject to foreign-court compulsion. | Not yet researched | none |
| Greecechecked 2026-09-13 | No indigenous trust or foundation institution exists; Greece has not ratified the 1985 Hague Convention on the Law Applicable to Trusts and on their Recognition (confirmed absent from HCCH's own status table of 14 contracting parties). The operative general-law creditor remedy is the Civil Code's fraud-of-creditors action, Astikos Kodikas Book One, Chapter 40, Arts. 939-946 -- a general fraudulent-conveyance doctrine applicable to any debtor's transfer, not a trust-specific mechanism. | 1946 (Civil Code took effect 23 February 1946); Arts. 939-946 themselves show no amendment since original enactment. | 5 years from the date of the alienation/transfer (Art. 946: the rescission action is time-barred after five years from the transfer). A separate 1-year rule (Art. 941 para. 2) governs only a rebuttable presumption of the transferee's knowledge for close relatives, not the action's overall limitation period. | On the challenging creditor generally, but what must be proven varies: for a transfer FOR VALUE, the creditor must show the transferee knew the debtor was transferring to the creditors' detriment (Art. 941), with a rebuttable presumption of knowledge for close relatives; for a GRATUITOUS transfer, the transferee's knowledge is not required at all (Art. 942). | No heightened standard is stated anywhere in Arts. 939-946; ordinary civil standard applies by default. | recognized, for EU member-state judgments (the non-EU route is not addressed here -- Greece's own Code of Civil Procedure would separately govern non-EU exequatur, but no official/authoritative source for those specific articles was fetched this session). As an EU member state, Greece is bound by the Brussels I Recast Regulation (EU) No 1215/2012, which applies without any special procedure: a judgment from another EU member state is recognised automatically (Art.36(1)) and enforceable without a declaration of enforceability (Art.39). | none -- full-text review of Arts. 939-946 found no bond or security-deposit requirement of a challenging creditor. | none -- full-text review found no duress/flight clause; structurally inapplicable given the lack of any domestic trust/foundation vehicle or trustee for such a clause to attach to. | Not yet researched | none |
| Uruguaychecked 2026-09-13 | Ley N. 17.703 de 27 de octubre de 2003 (Ley de Fideicomiso) -- Uruguay's Trust Law; a general commercial/civil trust vehicle, not a dedicated asset-protection statute. | 2003 (promulgated 27 October 2003, published in the Diario Oficial 4 November 2003). IMPO's page is marked 'Documento Actualizado'. | 1 year from when the creditor(s) become aware of the transfer (Codigo Civil Art.1296: la accion de que habla este articulo, expira en un ano contado desde que el acreedor o acreedores supieren la enajenacion); for transfers registered in the corresponding Registry, the period instead runs from the date of registration. | On the challenging creditor -- Art. 7: creditors need only establish the settlor's fraud, except where the transfer's gratuitous intent must be excluded. | No heightened standard is stated anywhere in Ley 17.703; ordinary civil standard applies by default. | recognized. Codigo General del Proceso Arts.538-539: a foreign judgment must be recognized and executed in Uruguay without merits review, conditioned on Art.539's formal requirements (authentic/legalized copy, translation if needed, originating court's international jurisdiction, proper notice and defense, res judicata in the state of origin, not manifestly contrary to Uruguay's international public order). Not treaty-conditioned; not a merits re-litigation. | none -- full-text search found no creditor bond/deposit-before-suit requirement (the statute's only guarantor-type references concern the trustee being PROHIBITED from acting as guarantor for the trust, an unrelated concept). | none -- full text reviewed, no duress/flight clause addressing fiduciary obligations under foreign-court compulsion. | Not yet researched | exemption-based |
| Panamachecked 2026-09-13 | Ley No. 25 de 12 de junio de 1995 ('Por la cual se regulan las fundaciones de interes privado') -- Private Interest Foundation Law. | 1995 | 3 years from the date of the contribution or transfer to the foundation (Art. 15). | On the challenging creditor. Art. 15 grants standing to the founder's (or a third party's) creditors to challenge a contribution/transfer to the foundation where it constitutes an act in fraud of creditors ('acto en fraude de acreedores'). | Ordinary civil standard -- no heightened evidentiary standard is stated anywhere across Ley 25/1995's 37 articles for the Art. 15 fraud challenge. | recognized. Codigo Procesal Civil (Ley 402 de 2023) Art.678: a treaty's terms govern when one exists; absent a treaty, the judgment may be executed in Panama unless proof that the foreign state does not reciprocally enforce Panamanian judgments -- if the foreign state doesn't reciprocate, the judgment has no force in Panama. Art.679 adds formal gates (personal-nature claim; no default judgment absent proper notice; underlying obligation lawful in Panama; authentic copy) -- a formal exequatur review before the Supreme Court's Sala Cuarta (Art.680), not a re-litigation of the merits. NOTE: this Ley 402/2023 fully repealed the old Codigo Judicial's civil-procedure books; any other citation in this site to 'Codigo Judicial, Libro IV' for Panama civil procedure is now stale. | none -- a full-text search across all 376 lines found no creditor bond/deposit-before-suit requirement. | none -- confirmed absence across all 37 articles; no duress/flight clause addresses Foundation Council obligations under foreign-court compulsion. | Not yet researched | firewall -- Art. 11: the foundation's patrimony is legally separate from the founder's personal assets and may not be seized, attached, or made subject to a precautionary measure, except for the foundation's own obligations or beneficiaries' legitimate rights, subject to the Art. 15 three-year fraud window. |
| United Arab Emirates — Mainlandchecked 2026-09-13 | Federal Decree-Law No. (31) of 2023 Concerning Trust. | 2023 | No specific look-back/limitation period is stated for the debt-evasion nullification ground (Art. 39(1)(b): the Court may nullify a trust if proven that its purpose was 'the evasion of the Settlor from paying debts, taxes, or any other financial obligations'). This is distinct from Art. 52's 3-year/15-year limitation periods, which govern lawsuits against a trustee for breach of trust specifically, not this nullification ground. | On the party seeking nullification (typically the creditor alleging debt evasion), per Art. 39(1). A rebuttable presumption against forgery/coercion/fraud/deception in the trust's creation arises once the Trust Instrument is registered and a Trust Validity Certificate issued, shifting the practical burden onto the challenger to rebut that presumption with evidence (Art. 39(1)(a)). | No heightened standard is stated anywhere in Federal Decree-Law No. 31 of 2023; ordinary civil proof is presumed to govern by default. | Not yet researched | none -- no bond/deposit-before-suit requirement found in Federal Decree-Law No. 31 of 2023. | none -- no duress/flight clause protecting a trustee against foreign-court compulsion exists; Art. 39(1)(a)'s 'coercion' ground addresses invalidating the trust's creation where the settlor was coerced, a distinct concept from a protective duress clause. | Not yet researched | none -- and affirmatively anti-shielding: Art. 39(1)(b) makes a trust used to evade debts, taxes, or financial obligations NULLIFIABLE outright, the functional opposite of a creditor-defeat/firewall/exemption-based regime. |
| United Arab Emirates — DIFCchecked 2026-09-13 | Trust Law, DIFC Law No. 4 of 2018 (repeals and replaces Trust Law No. 11 of 2005). | 2018 (DIFC Law No. 4 of 2018). Art. 5 defers exact enactment day to a separate Enactment Notice not fetched this session. | Not yet researched | On the challenging creditor -- Art. 14(4): burden of proof rests with the creditor. | No heightened standard is stated anywhere; ordinary civil standard applies by default. | re-litigate -- Art. 16: a foreign judgment shall not be recognised/enforced/give rise to estoppel insofar as inconsistent with Articles 14 and 15. | none -- full-text review found no bond/deposit-before-suit requirement. | none in the Nevis-style protective sense -- Arts. 25(1)(g), 62(4) let a trustee declare a person incapacitated if under duress; no clause directs a fiduciary to disregard a foreign-court-compelled demand. | Not yet researched | firewall |
| United Arab Emirates — ADGMchecked 2026-09-13 | Foundations Regulations 2017 (Abu Dhabi Global Market) -- ADGM has no separate trust-specific statute; Foundations are ADGM's asset-holding vehicle. | 2017; enactment day not machine-extractable this session; secondary sources report 14 August 2017, not independently confirmed against the primary document. | Not yet researched | On the challenging creditor -- Section 30(3): burden of proof rests with the creditor. | No heightened standard is stated anywhere; ordinary civil standard applies by default. | re-litigate -- s.29(5): a foreign judgement shall not be recognised or enforced insofar as inconsistent with subsections (3)-(4). | none -- full-text review found no bond/deposit-before-suit requirement. | none -- zero occurrences of 'duress' anywhere in the Regulations (unlike RAK ICC's 2025-amended Reg. 25A). | Not yet researched | firewall |
| United Arab Emirates — RAK ICCchecked 2026-09-13 | RAK ICC Foundations Regulations 2019, as amended by the 2025 Amendments (in force 31 July 2025). No separate trust-specific statute exists -- confirmed via RAK ICC's own Rules & Regulations listing; contrary to the original unverified lead, there is no RAK ICC International Trusts Regulations. | 2019 (base Regulations); amended 2025, in force from 31 July 2025 (Reg. 1(1)). | 3 years -- NEW Reg. 68A (2025): no action to set aside a Foundation's establishment/disposition more than 3 years from that date (68A(1)); a separate 3yr period applies to a pre-existing-interest claim (68A(2)). | On the challenging creditor -- amended Reg. 7(4): burden of proof rests with the creditor. | No heightened standard is stated anywhere in the Regulations as amended; ordinary civil standard applies by default. | re-litigate -- amended Reg. 7(5)-(8): foreign judgment not recognised/enforced if inconsistent with Regs. 7-8; uniquely, a Foundation Officer subject to a foreign court order (that court not dismissing the action) automatically and immediately loses all authority, without further court order -- a self-executing officer-removal mechanism not seen in DIFC/ADGM. | none -- full text reviewed, no bond/deposit-before-suit requirement found. | Yes -- NEW Reg. 25A (2025): a person granted power to demand/request an act from a Founder/Contributor/Qualified Recipient/Foundation Officer must recognise only demands from persons acting of their own free will, not under compulsion of any court other than the RAK ICC Court/Registrar. A genuine Nevis-s.16-style duress clause, unique among the three UAE zones this wave (DIFC and ADGM both 'none'). | Not yet researched | firewall |
| Singaporechecked 2026-09-13 | No dedicated asset-protection-trust statute. Trustees Act 1967, ss.86-87, confirm 'to avoid doubt' that any settlement/disposition of property on trust that is a transaction at undervalue or unfair preference is subject to the Insolvency, Restructuring and Dissolution Act 2018 (IRDA) -- s.87(1) for individuals (IRDA ss.361-365), s.87(2) for bodies corporate (IRDA ss.224-227). No independent trust-specific creditor-defeat mechanism exists. | Trustees Act 1967 (current consolidated version last amended 20 Jun 2025 by Act 42 of 2024); ss.86-87's cross-reference to IRDA took effect 30 July 2020. | 3 years ending on the day the bankruptcy application is made (IRDA s.363(1)(a)(ii)); or, where the application is based on a s.312(d) presumption, the period commencing 3 years before that application (s.363(1)(a)(i)). | Not expressly allocated in either statute. Under IRDA s.361(1) the Official Assignee applies to the Court for an order -- as applicant, the Official Assignee bears the burden by default under ordinary civil procedure; no statutory burden-shifting provision exists. | No heightened standard is stated in IRDA ss.361-365 or Trustees Act ss.86-87; ordinary civil standard applies by default. | recognized -- via statutory registration for judgments of superior courts of countries the Minister has gazetted as reciprocating (s.3, Reciprocal Enforcement of Foreign Judgments Act 1959): on application the court shall, subject to proof of the prescribed matters, order the judgment to be registered (s.4(2)), unless the judgment has already been wholly satisfied, discharged, or is unenforceable in its country of origin (s.4(3)). For non-gazetted countries, s.12 empowers the Minister to make foreign judgments of that country unenforceable in Singapore absent reciprocity; the common-law action-on-the-judgment-debt route is the applicable non-statutory alternative. | none -- no bond or security-deposit requirement of a creditor found in Trustees Act ss.86-87 or IRDA ss.361-365. | none -- no duress/flight clause protecting a trustee against foreign-court compulsion exists in either statute. | Not yet researched | none |
| Hong Kongchecked 2026-09-13 | No dedicated asset-protection-trust statute. Trustee Ordinance (Cap. 29), Part 4D 'Reserve Power and Transfer of Movable Property' (ss.41X 'Reserve power of settlor', 41Y 'Transfer of movable property not affected by foreign law of inheritance') is the closest on-point provision -- a forced-heirship/succession-law conflict-of-laws shield, not a creditor-defeat regime. | Part 4D added by Ordinance 13 of 2013 s.27, commencement date 1 December 2013; s.41Y(1)(b) amended by Ordinance 14 of 2025 s.99. | No fixed number of years runs from the date of the transfer itself. Cap 219 (Conveyancing and Property Ordinance) s.60(1) -- the operative fraudulent-disposition provision -- states no lookback period of its own; full text of ss.59-61 reviewed and confirms this. The general Limitation Ordinance (Cap 347) governs when such an action becomes time-barred: the ordinary 6-year period for tort/simple-contract actions (s.4(1)) is POSTPONED under s.26(1), which provides that where the action is based upon the defendant's fraud, the limitation period does not begin to run until the plaintiff has discovered the fraud, or could with reasonable diligence have discovered it. The clock runs from discovery, not from the transfer date -- structurally identical to the discovery-postponement approach used elsewhere in this matrix (cf. united-kingdom, Limitation Act 1980 s.32(1); Cap 347 s.26 shares the same statutory lineage, citing "[cf. 1939 c. 21 s. 25 U.K.]"). | Not yet researched | Not yet researched | recognized (for gazetted/designated countries only) via statutory registration -- not universal, and not a merits re-litigation. Cap 319 (Foreign Judgments (Reciprocal Enforcement) Ordinance) s.3 empowers the Chief Executive in Council to extend the Ordinance by gazetted order only to specific foreign countries/Commonwealth parts giving Hong Kong judgments reciprocal treatment. For a qualifying judgment, a judgment creditor may apply within 6 years of the judgment to register it, and the court 'shall... order the judgment to be registered' (s.4(1)) -- registration is mandatory once conditions are met, not discretionary re-litigation. Registration may be set aside only on narrow grounds: want of jurisdiction, inadequate notice, fraud, or public policy (s.6(1)(a)); s.10 gives even an unregistered qualifying judgment conclusive effect between the parties. Judgments from non-designated countries fall outside this Ordinance entirely. | none -- full-text review of Cap 29 found no creditor bond/deposit-before-suit requirement. | none -- full-text review of Cap 29 found zero occurrences of 'duress'; no protective clause against foreign-court compulsion exists. | Not yet researched | firewall |
| Estoniachecked 2026-09-13 | No domestic trust or foundation institution exists; Estonia has not ratified the 1985 Hague Convention on the Law Applicable to Trusts and on their Recognition (confirmed absent from HCCH's own status table). The operative general-law creditor remedy is the Bankruptcy Act (Pankrotiseadus), Chapter on 'Recovery' Sections 109-119. | Bankruptcy Act passed 22 January 2003, entered into force 1 January 2004. Recovery provisions (SS109-119) amended through RT I, 01.03.2023, 3. | Compound (S110(1)): 1yr if other party knew/should have known of damage; 3yr if intentional damage + knowledge; 5yr if intentional + connected party + knowledge. 6-month knowledge presumption (S110(2)). Claim filed within 3yr of bankruptcy declaration (S118(2)). | On the trustee, who alone may file the recovery claim (S118(1)): must show the other party knew/should have known of damage. Within 6 months before trustee appointment, knowledge is presumed (S110(2)). | No heightened standard is stated anywhere in SS109-119; ordinary civil standard applies by default. | recognized. (1) EU member-state judgments: Brussels I Recast Regulation (EU) 1215/2012 applies directly -- automatic recognition, Art.36(1). (2) Non-EU judgments: Estonia's Code of Civil Procedure (Tsiviilkohtumenetluse seadustik) §620(1) provides that a foreign civil judgment is subject to recognition in Estonia as a general rule, unless one of six listed exceptions applies (public-policy contrariety; due-process/service failure; conflict with an Estonian judgment; conflict with an earlier-recognized foreign judgment; conflict with an unrecognized-but-recognizable earlier foreign judgment; lack of proper international jurisdiction by the foreign court). §620(3) confirms recognition requires no separate court proceeding; a separate declaration-of-enforceability procedure (§621-623) is needed only to enforce, not merely recognize, the judgment. | none -- full-text review of SS109-119 found no creditor bond/deposit-before-suit requirement. | none -- zero occurrences of 'duress' anywhere in the Act; no protective clause against foreign-court compulsion exists. | Not yet researched | none |
| Vanuatuchecked 2026-09-13 | Foundation Act No. 38 of 2009 (Consolidated Edition 2026) -- Vanuatu's self-settled entity vehicle. No separate 'International Trust Act' exists (an unsubstantiated offshore-marketing claim); Trust Companies Act [CAP 69] and Unit Trusts Act No. 36/2005 regulate professional trustee licensing/unit trusts, neither a self-settled AP vehicle. | 2009 (Act 38 of 2009; commenced 28 April 2010); amended Act 20/2017 and Act 32/2018; current Foundation Consolidation Edition 2026. | N/A | N/A | N/A | re-litigate -- s.27(1)-(2): a transfer valid under Vanuatu law is not void merely because foreign law disagrees, nor because it contravenes a foreign judicial/administrative order intended to enforce a foreign claim (e.g. forced-heirship). A foreign judgment premised on such inconsistent foreign law has no direct effect. | none -- full text reviewed, no bond or security-deposit requirement of a creditor found. | none -- full text reviewed, zero occurrences of 'duress'; no clause protecting a councillor/guardian against foreign-court compulsion exists. | Not yet researched | none |
| United Kingdomchecked 2026-09-13 | No dedicated asset-protection-trust statute. English trust law is indigenous, but protection against the settlor's own creditors is governed by the general Insolvency Act 1986: s.423 (transactions defrauding creditors, any victim, no insolvency required) and ss.339/424 (bankruptcy-only undervalue route). | 1986 (Insolvency Act, royal assent 25 July 1986); s.423(1)(b) amended 2005 but the operative test unchanged since enactment. | No fixed year-count runs from the date of transfer. Under s.423 Insolvency Act 1986 ("transactions defrauding creditors") the limitation period is governed by the general Limitation Act 1980, and s.32(1) of that Act postpones the start of the limitation clock until the claimant discovers the fraud/concealment (or could with reasonable diligence have discovered it) -- not from the date of the original transfer. The practical look-back is open-ended in principle, bounded only by discoverability. | On the applicant (a 'victim', or a trustee/liquidator/official receiver on victims' behalf per s.424) to satisfy the court the transaction aimed to put assets beyond a claimant's reach or otherwise prejudice their interests (s.423(3)). | No heightened standard in ss.339/423/424; ordinary civil standard (balance of probabilities) applies. | recognized -- but genuinely conditional on the judgment's country of origin (patchwork regime, no single clean characterization). (1) Hague 2019 Judgments Convention states (in force for the UK from 1 July 2025, covering the EU minus Denmark, Ukraine, Uruguay) -- recognized/enforced under the Convention's own limited refusal grounds. (2) Countries with a reciprocal arrangement extended under the Foreign Judgments (Reciprocal Enforcement) Act 1933 or the older Administration of Justice Act 1920 (mostly Commonwealth) -- recognition via statutory registration, not a fresh trial on the merits. (3) Every other country (including most US states absent a treaty) -- common law governs: the judgment creditor must bring a fresh English action suing on the foreign judgment as a debt; English courts do not re-examine the foreign merits, but a new proceeding is required. Post-Brexit, the EU Brussels I Recast Regulation no longer applies to the UK at all. | none -- ss.339, 423, 424 reviewed in full, no bond or security-deposit requirement. | none -- ss.339, 423, 424 reviewed in full, no duress/flight clause protecting a trustee against foreign-court compulsion exists. | Not yet researched | none |
| Wyomingchecked 2026-09-13 | Qualified Spendthrift Trust Act, Wyo. Stat. Ann. SS4-10-510 to 523 (asset-protection core); limitations at S34-14-210(a)-(b); foreign-judgment/trustee-compulsion provision at S4-10-507.1. | 2007 (DAPT provisions enacted); S4-10-507.1 part of the same Article 5. | Via Title 34-14-210: general rule (a) 2yr from transfer (or 6mo discovery), EXCEPT (b) for a qualified-spendthrift-trust transfer, claim extinguishes 120 days after settlor/trustee notice to creditors (carve-out at (b)(iii) preserves full (a) period for a pre-transfer-asserted claim). Transcluded, independently re-verified this session. | On the challenging creditor -- confined to Uniform Fraudulent Transfer Act claims, clear-and-convincing burden (SS4-10-514, 4-10-517(a)). | Clear and convincing evidence -- no beyond-reasonable-doubt-tier standard. | re-litigate -- S4-10-507.1(a): no judgment/decree/order of any court other than Wyoming shall be enforced against trust property unless a Wyoming court determines enforcement is consistent with this article's restrictions. FRESH FIND, not in the existing site matrices. | none -- the only 'bond' provision (S4-10-702) is an ordinary trustee-performance bond, unrelated to a creditor posting bond before suit. | Yes -- S4-10-507.1(b): a trustee/protector/advisor shall not be liable for failing to comply with any judgment of a court other than Wyoming believed in good faith to be inconsistent with the trust's terms or this act. Functionally equivalent to Nevis s.16. FRESH FIND. | Not yet researched | creditor-defeat |
| Nevadachecked 2026-09-13 | Spendthrift Trust Act of Nevada, NRS Chapter 166. | Enacted 1939 base act; DAPT-specific provisions added later; current chapter spans NRS 166.010-166.180. | 2 years after transfer (or 6 months after discovery, later) for a pre-existing creditor; 2 years flat for a subsequent creditor (NRS 166.170(1)(a)-(b)). | On the challenging creditor -- NRS 166.170(3): must prove by clear and convincing evidence the transfer was fraudulent or violates a legal obligation owed to the creditor. | Clear and convincing evidence (NRS 166.170(3)) -- no beyond-reasonable-doubt-tier standard. | re-litigate (with a treaty/reciprocity carve-out) -- Nevada has adopted the Uniform Foreign-Country Money Judgments Recognition Act, NRS 17.700-17.820. A foreign-country money judgment is entitled to recognition (and thereafter enforced exactly as a Nevada judgment) only if it satisfies NRS 17.750's standards (impartial tribunals, proper jurisdiction, adequate notice, no fraud, not repugnant to public policy) -- not automatically enforced; recognition is obtained via a dedicated procedure under NRS 17.770. | none -- full-text search of NRS Chapter 166 found zero occurrences of 'bond'. | none -- full-text search found zero occurrences of 'duress'/'compulsion'; no trustee-compulsion protection clause exists (contrast Wyoming). | Klabacka v. Nelson, 133 Nev. 164, 394 P.3d 940 (2017) -- the Nevada Supreme Court held Nevada self-settled spendthrift trusts (SSSTs) under NRS Chapter 166 are protected even against a beneficiary's own child- and spousal-support obligations that were not known at the time the trust was created, expressly rejecting the Restatement (Third) of Trusts Sec.59 exception as inconsistent with Nevada's statutory framework and legislative history. | firewall |
| South Dakotachecked 2026-09-13 | South Dakota Qualified Dispositions In Trust, SDCL Chapter 55-16. | Enacted 2005 (SL 2005, ch 261); amended through 2026 (SL 2026, ch 198). | Pre-existing creditor: later of 2yr after transfer or 6mo after discovery. Subsequent creditor: 2yr flat (S55-16-10(1)-(2)). | On the challenging creditor -- S55-16-10: burden to prove by clear and convincing evidence is upon the creditor. | Clear and convincing evidence -- no beyond-reasonable-doubt-tier standard. | re-litigate -- S55-16-9: no action, including one to enforce a judgment by any court or adjudicative body, may be brought against qualified-disposition property unless the transfer was made with intent to defraud that specific creditor. 'Any court' isn't SD-limited, requiring a fresh fraud showing. Rests on a substantive reading, not a dedicated clause -- flagged for validator attention. | none -- SS55-16-9/10 reviewed in full, no bond/deposit-before-suit requirement; chapter's 16-section TOC has no bond-related title. | none -- no section among the chapter's 16 concerns trustee duress/compulsion protection; SS55-16-9/10's text contains no such clause. | Netter v. Netter, AC 46484 (Conn. App. Ct., argued 2025-03-18, officially released 2025-10-21) -- a Connecticut Appellate Court decision holding that three self-settled domestic asset-protection trusts the husband created during marriage and administered under South Dakota law were nonetheless divisible marital property in the Connecticut divorce, because Connecticut public policy does not recognize self-settled spendthrift shields against a spouse, regardless of the trust's South Dakota situs. (A sister-state court declining to honor South Dakota's DAPT protection under its own forum's public policy -- analogous in kind to this matrix's cook-islands cell, which likewise cites a foreign (9th Circuit) court's decision testing the regime, not a Cook Islands court's own.) | firewall |
| Delawarechecked 2026-09-13 | Delaware Qualified Dispositions in Trust Act, 12 Del. C. SS3570-3576. | Enacted 1997 (71 Del. Laws, c.159) -- one of the two founding DAPT jurisdictions alongside Alaska. | 4 years for post-disposition claims (actual intent to defraud required); pre-existing claims cross-reference 6 Del. C. S1309. | On the challenging creditor, clear and convincing evidentiary burden for actual-intent-to-defraud claims. | Clear and convincing evidence -- no beyond-reasonable-doubt-tier standard. | recognized (subject to statutory grounds for non-recognition) -- Delaware has adopted the Uniform Foreign-Country Money Judgments Recognition Act, 10 Del. C. Ch.48 (Sec.4801-4811). Absent a listed non-recognition ground, a court of this State shall recognize a foreign-country judgment to which this chapter applies (Sec.4803); a recognized judgment becomes conclusive between the parties and enforceable exactly as a Delaware judgment (Sec.4810). Action to recognize must commence within 15 years or the judgment's effective period abroad, whichever is earlier (Sec.4811). | none -- full-text search found zero occurrences of 'bond'. | none -- full-text search found zero occurrences of 'duress'/'compulsion'; no trustee-compulsion protection clause exists. | In the Matter of the CES 2007 Trust, C.A. No. 2023-0925-SEM (Del. Ch., report dated 2025-05-02, Magistrate Selena E. Molina) -- dismissed a creditor's petition to void the spendthrift provision of a Delaware Qualified Dispositions in Trust Act (12 Del. C. Sec.3570-76) trust, holding the trust met every statutory requirement for Asset-Protection-Trust status and that neither the public-policy nor merger doctrine from Kulp v. Timmons, 944 A.2d 1023 (Del. Ch. 2002), applied. | firewall |
| Floridachecked 2026-09-13 | No self-settled domestic asset-protection trust vehicle exists. Fla. Stat. S736.0505(1)(b): for an irrevocable trust, a creditor/assignee of the settlor may reach the maximum amount distributable to/for the settlor's benefit -- opposite of DAPT protection. A revocable trust is fully reachable per (1)(a). Independently confirmed this session. | Florida Trust Code, current codification; S736.0505(1)(c) carries a tax-reimbursement savings clause not affecting the core no-DAPT rule. | N/A | N/A | N/A | recognized (subject to statutory grounds for nonrecognition) -- Florida's Uniform Out-of-Country Foreign Money-Judgment Recognition Act (Fla. Stat. ss.55.601-55.607) provides that a qualifying out-of-country judgment is conclusive between the parties (s.55.604) once filed and recorded with the clerk of court, with notice to the judgment debtor -- no separate registration ORDER is required, only filing plus the s.55.605 grounds for nonrecognition (impartial-tribunal/due-process failure, lack of personal or subject-matter jurisdiction, inadequate notice, fraud, public-policy repugnance, conflicting judgment, forum-selection-clause violation, lack of reciprocity, certain foreign defamation judgments). | none -- structurally absent; there is no self-settled protection mechanism for a creditor to post bond against. | none -- structurally inapplicable; no self-settled trust vehicle exists for a trustee-compulsion clause to protect. | Menotte v. Brown (In re Brown), 303 F.3d 1261 (11th Cir. 2002) -- the leading federal appellate decision applying Florida's self-settled-trust doctrine: a settlor cannot shield her own retained trust interest from her creditors via a spendthrift clause, even absent fraud or insolvency at the time of the transfer. Applies Florida common law (Croom v. Ocala Plumbing & Elec. Co., 57 So. 243 (Fla. 1911); Waterbury v. Munn, 32 So. 2d 603 (Fla. 1947)), the same no-self-settled-protection rule this row's regime_type cell cites in its later Fla. Stat. Sec.736.0505 codification. | none |
| Puerto Ricochecked 2026-09-13 | Ley Num. 219 de 31 de agosto de 2012, segun enmendada ('Ley de Fideicomisos') -- Puerto Rico Trust Act. | 2012 | 4 years (general personal-action prescription default, Codigo Civil de Puerto Rico de 2020 Art.1203 / 31 L.P.R.A. Sec.9495: las acciones personales de todo tipo prescriben a los cuatro anos, salvo cuando la ley fija un plazo distinto) -- the accion rescisoria/pauliana (Arts.298-301) states no action-specific period of its own, so this general default governs. Runs from when the creditor knows or should know of the right to claim and the debtor's identity (Art.1190), since Arts.298-301 also state no action-specific commencement rule. | Art.298 (31 L.P.R.A. Sec.6231) presumes fraud -- shifting the practical burden to the transferee/debtor to rebut -- in four enumerated circumstances: (a) the transfer postdates the creditor's claim, or evades the consequences of a wrongful act; (b) it excludes/impedes incorporation of an asset into or from the debtor's patrimony, or grants new security on a prior debt; (c) it produces or aggravates the debtor's insolvency; or (d) it impairs the creditor's remedy -- itself presumed for transfers among relatives within the 4th degree of consanguinity/2nd of affinity, gratuitous transfers, and onerous transfers made after judgment or a writ of attachment. Outside those circumstances, the creditor bears the ordinary burden of proving fraud under Art.299. | none -- Arts.296-301 reviewed in full; no heightened evidentiary standard (e.g. clear-and-convincing) is stated for the accion pauliana. The Code structures proof through the Art.298 presumptions (shifting persuasion in four defined circumstances) rather than a separate standard-of-proof doctrine. | recognized -- Act 219-2012 itself contains no non-recognition clause; as a US jurisdiction, sister-state judgments are governed by the U.S. Constitution's Full Faith and Credit Clause (Art. IV, Sec. 1), with comity principles applying to genuinely foreign-country judgments. | none -- a full-text search across all 1720 lines found no bond/deposit-before-suit requirement. | none -- a full-text search across all 1720 lines found no duress/flight clause addressing fiduciary obligations under foreign-court compulsion. | Not yet researched | exemption-based. Art. 2 (32 L.P.R.A. Sec.3351a) makes the trust patrimony 'exento' (exempt) from the individual or collective action of the settlor's, beneficiary's, and trustee's own creditors while the trust subsists, subject to Art. 6 -- EXCEPT for a revocable trust, where property subject to the settlor's still-live power to revoke or withdraw remains reachable by the settlor's creditors to the same extent as if the trust did not exist. This is the self-settled-APT mechanism this session's first pass (limited to Arts. 40-44, 72-75) had not located. |
Hover column headers to see field definitions. Hover cell text to see source notes. Typed unknowns (e.g., “Portal not observable”) are methodological limits, not data gaps.
Research scope
Rows are the jurisdictions on the Private Pierce international roster, plus six US jurisdictions — Wyoming, Nevada, South Dakota, Delaware, Florida, and Puerto Rico. The US rows are here because they legislate on this same axis and are the jurisdictions readers most often hold up against an offshore option; putting them in the same table on the same fields lets the statutory terms be read against each other instead of described in two separate vocabularies. Where a jurisdiction runs more than one regime, the divergent regimes appear as their own rows directly beneath the parent. Cells that read as not established or unknown are typed unknowns — the research pass did not confirm that field against an official source, the reason is on hover, and they will be backfilled through this same data file rather than by rewriting this page.
How to read this matrix
Each row is a jurisdiction. statute_name and statute_year identify the authorizing act and when its asset-protection provisions entered the law. fraudulent_transfer_lookback_years records the window in which a creditor may attack a transfer; burden_of_proof and standard_of_proof record who must prove what, and how convincingly. foreign_judgment_recognition records whether the jurisdiction gives effect to a judgment obtained elsewhere, creditor_bond_requirement whether a challenging creditor must post security, duress_clause whether the statute addresses trustee compulsion, and regime_type how the jurisdiction's regime is characterized. notable_case_law names decisions that have tested the statute. Sub-rows such as the Nevis and Federation rows under St. Kitts & Nevis, or the free-zone rows under the United Arab Emirates, are separate regimes within one parent jurisdiction and carry their own values.
What this page does not claim
- It does not predict outcomes. Describing a statute is not predicting how a court applies it, and the conflict-of-laws question — whether a court outside the jurisdiction will give effect to that statute against a creditor — is fact-specific and outside this matrix entirely.
- It does not rank or recommend. There is no score, no ordering, and no statement that any jurisdiction suits any reader.
- It does not guarantee currency. Foreign law changes, sometimes without a consolidated text following quickly; verify each cell against its linked official source and with local counsel.
Sources
Each row links to one primary official domain for that jurisdiction, chosen as its lead source. Every published cell carries its own pinpoint citation, source URL, and the first segment of the snapshot hash of the document it was read from, visible on hover; the snapshots themselves are retained on file. Where a jurisdiction publishes a consolidated text, the consolidation date it was read at is recorded with the underlying matrix rather than restated here. The full source taxonomy lives at /about/source-registry/, and the research method at /about/methodology/.
Not legal advice
Private Pierce is not a law firm and does not provide legal advice.
Nothing on this page is legal, tax, or immigration advice, and it is not a recommendation to use any jurisdiction; foreign law is described from official sources as published and may have changed — consult counsel licensed in the relevant jurisdiction.
Frequently asked questions
What does this matrix record?
For each jurisdiction, the statute that authorizes an asset-protection trust and the conditions that statute sets: the fraudulent-transfer lookback period, which party carries the burden of proof, the standard of proof applied, whether a creditor must post a bond, whether foreign judgments are recognized, and whether the statute addresses trustee duress. Each cell cites the jurisdiction's own official source.
Why do US states appear next to offshore jurisdictions?
Because the same question — does this jurisdiction's own statute let a settlor be a protected beneficiary, and on what terms — is answerable for both. Wyoming, Nevada, South Dakota, Delaware, Florida, and Puerto Rico are recorded on the same fields as the international rows so the statutory terms can be read against each other rather than described in separate vocabularies.
What does "not established" mean in a cell?
It means the research pass did not locate a citable primary source for that field in that jurisdiction, and the cell is recorded as a typed unknown with its reason rather than filled with a guess. Hover the cell to read the reason. Those cells are scheduled for backfill and will update through the same data file this page reads.
Does a favorable statute mean a trust will hold up?
This matrix describes what each jurisdiction's statute says, as published by that jurisdiction. It does not resolve the separate, fact-specific conflict-of-laws question of whether a court elsewhere will apply that statute, and it is not a recommendation to use any jurisdiction. Consult counsel licensed in the relevant jurisdiction.
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