Tracing assets from China to France

The position in one paragraph

French real estate records are reliable, but the asset holdable in France is frequently not real estate at all.

An assurance-vie policy sits outside the estate and is treated separately from other assets under French law, which means it can be overlooked even when the property is traced. Identifying it requires looking at the financial records, not just the property register.

A typical situation

Funds have been transferred from China into a French assurance-vie policy and a property over a year.

Tracing only the property. Where wealth has been moved into insurance-wrapped products, the property search finds nothing while the assets remain intact.

What distinguishes this from a purely domestic case

The default regime is community of acquisitions, but a prenuptial agreement can switch the couple to separation of property — which changes everything.

On the China side, the connecting factor has to be established on the documents: A Chinese court can order disclosure and, in an appropriate case, preservation over assets located in China. Foreign-located assets need a separate route.

The practical sequence in a France-connected matter

1. Preserve first, investigate second — timing matters more than completeness
2. Assemble the documentary trail: transfers, property records, corporate filings, and communication showing intent
3. Apply for preservation over China-situated assets before they move
4. Where assets have gone abroad, plan how a foreign court or authority would be asked to act

Certification differs between judicial documents and notarial documents, so the document type has to be identified first.

How France documents are handled

Apostille from the court or chamber of notaries for judicial documents, or the prefecture.

France uses a communauté system with a well-developed prenuptial agreement practice, and the chosen regime governs the division.

The default community-of-acquisitions regime applies only if no registered agreement displaced it.

What has to be decided before filing

Preserve the China-side assets first, then examine the French financial records as well as the property register.

The boundary to plan around is this: Investigation powers do not extend extraterritorially; a Chinese court cannot order a foreign bank to disclose. Where value sits in France — typically property, company equity, assurance-vie policies — it is handled by agreement or by a separate route there, not by an order the Chinese court could enforce directly.

If your situation has a France element

Asset cases are won in the first two weeks. If you believe assets are being moved, send us what you have and we will say what preservation can realistically achieve.

Frequently asked questions