How a New Jersey Heir Used an Israeli Succession Order in US Probate Court

Background

The client's mother had divided her later years between New Jersey and Tel Aviv, dying intestate in early 2025. The Israeli side of her estate — an apartment in Bat Yam and two Israeli bank accounts — was handled by an Israeli attorney and concluded with a succession order from the Inheritance Registrar. That process, while slow, went smoothly.

The US side was smaller but unexpectedly complicated. The mother held a non-retirement investment account at a major New York brokerage with no beneficiary designation on file. Under US law, the account fell into her estate. The estate's executor — the client's brother, based in New Jersey — needed to establish legal authority over the US account to distribute it to the heirs.

The brokerage's legal team required documentation proving heirship. Because the mother had been domiciled partly in Israel, and the Israeli succession order was the governing probate instrument, the brokerage requested that document — properly apostilled and translated into English.

The Challenge

The first error happened quickly. The Israeli attorney had provided an apostilled copy of the succession order, helpfully, without being asked. The apostille had been issued by the Tel Aviv Magistrates Court.

That was wrong. Under the Hague Apostille Convention 1961, each signatory country designates specific competent authorities for issuing apostilles. For judicial and quasi-judicial documents in Israel — succession orders, will execution orders, court judgments — the competent authority is the Israeli Ministry of Justice Document Authentication Unit, not the court that issued the document. The Magistrates Court apostille was genuine but was not valid for use in a foreign jurisdiction. The brokerage's legal team rejected it.

The second problem emerged next. The heirs had commissioned a Hebrew-to-English translation from a local agency in New Jersey. The agency was reputable. The translation itself was accurate. But the document lacked a signed translator's affidavit — the certificate in which the translator personally attests to accuracy, completeness, and their own qualifications. US courts and major financial institutions routinely require this affidavit to recognize a translation as "certified." Without it, the translation was just a translation, not a certified one.

Two separate technical errors. Together, they added 11 weeks.

In Practice: Under the Hague Apostille Convention 1961, succession orders issued by the Israeli Inheritance Registrar (Rasham HaYerushot) require an apostille from the Israeli Ministry of Justice Document Authentication Unit — not from the district or magistrates court that issued or recorded the order. The Ministry of Justice fee is NIS 285 per document under the standard service, with a 5–7 business day processing time. The express service costs NIS 570 and is processed within 48 hours at the Tel Aviv branch.

What We Did

We obtained a new apostille directly from the Israeli Ministry of Justice Document Authentication Unit in Tel Aviv. Express service: 48-hour turnaround, NIS 570.

For the translation, we instructed a Hebrew-to-English translator holding certification from the American Translators Association (ATA). An ATA-certified translator's work is widely recognized by US courts and financial institutions as meeting the "certified translation" standard. The submission included the translated text, the ATA seal, and a signed affidavit of accuracy and professional standing.

Before filing anything, we contacted the brokerage's legal team directly to confirm their exact requirements. This is a step that most attorneys — and most clients doing this without counsel — skip. Every US financial institution has its own checklist. Assumptions cost time.

Their requirements: the original Hebrew succession order, the Ministry of Justice apostille, the ATA-certified English translation with affidavit, certified copies of the heirs' passports, and a one-page explanatory letter describing the Israeli probate process and the authority of the Inheritance Registrar under Section 17 of the Succession Law 1965.

That last item — the explanatory letter — is not legally required. US financial institutions are simply not familiar with how Israeli intestate succession works. A clear, one-page description of what a succession order is, who issues it, and what authority it confers on heirs cuts through the confusion that can otherwise lead to additional back-and-forth review rounds.

For detailed guidance on the apostille process for Israeli documents, see how to apostille Israeli documents.

The Outcome

The brokerage accepted the resubmitted package without further questions. The US account was released and transferred to the heirs within six weeks of resubmission. Total account value: approximately $190,000.

The extra 11 weeks cost the estate roughly $4,000 in additional attorney time and translation fees — entirely avoidable with correct guidance from the outset.

Key Takeaways

What this case illustrates for US heirs working across Israeli and American probate systems:

1. The correct apostille authority for Israeli court documents is the Israeli Ministry of Justice, not the court that issued the document. Confirm this before ordering any apostille — it is a common error and an expensive one.
2. A "certified translation" in the US context means a signed translator's affidavit, not merely a stamp or letterhead from a translation agency. ATA-certified translators provide translations that US courts and financial institutions consistently accept.
3. Before submitting foreign documents to any US financial institution, confirm in writing exactly what format is required. Each institution maintains its own checklist. Filing blind — even with technically correct documents — risks rejection.
4. An explanatory legal opinion letter describing the Israeli succession process is not mandatory, but it removes a common obstacle. US institutions unfamiliar with Israeli law benefit from plain-language context.
5. Israeli succession orders, once correctly apostilled and translated, are accepted by US courts and financial institutions as valid foreign probate documents. The process is not inherently difficult — the complexity lies in procedural compliance, not legal substance.

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Facing a Similar Situation?

If you are dealing with an Israeli estate that connects to US assets, or need Israeli court documents certified for use in American proceedings, both sides have precise technical requirements that are easy to get wrong.

Contact us for a confidential consultation about your Israeli inheritance and US estate coordination.