Lessons by a Time Traveler Writing From 2030: The Unclaimed Property Mistakes Of2025 and How to Prepare Now

Prepared by: Josiah S. Osibodu, CPA, CFE, AI Consultant
JSO Consulting Services, LLC (dba Moyer & Osibodu Unclaimed Property Consulting Services, LLC)
December 19, 2025

In 2030, unclaimed property is no longer discussed as a narrow compliance obligation. It is
understood—correctly—as a window into how an organization manages value, data,
systems, accountability, and trust. That understanding did not exist in 2025.

Looking back, the most striking feature of 2025 is not negligence. Most organizations
believed they were compliant. The failure was subtler and far more dangerous: unclaimed
property was misunderstood as static law applied to static assets, when it was in fact a
dynamic system governing how value is created, held, forgotten, and reclaimed inside
increasingly complex enterprises.

The enforcement wave of the late 2020s did not arrive because laws suddenly changed. It
arrived because business models, technology, and data architectures changed faster than
compliance thinking did.

From the vantage point of 2030, ten mistakes explain nearly every painful audit,
settlement, and reputational shock that followed.

Mistake #1: Assuming State Enforcement Would Remain Slow, Manual, and
Fragmented

In 2025, enforcement still looked familiar: periodic audits, long timelines, limited
coordination. Organizations assumed tomorrow would resemble yesterday.

It did not.

Between 2026 and 2029, states modernized aggressively. Audit selection became data
driven. Filing gaps, inconsistent reporting patterns, negative reports in high-risk
jurisdictions, and large customer populations with low reported property volumes became
automated signals. Multi-state audits became common. Third-party auditors,
compensated on contingency-basis, deployed analytics at scale.

The result was not harsher enforcement—it was faster, broader, and more precise.

From 2030, the lesson is clear: enforcement did not become aggressive; it became
intelligent.

Mistake #2: Clinging to an Outdated Definition of “Property”

In 2025, many organizations still equated unclaimed property with paper checks and
dormant bank accounts. Meanwhile, value was quietly accumulating elsewhere: digital
wallets, subscription credits, refunds, marketplace seller balances, loyalty points,
promotional balances, and custodial digital assets.

States did not need new legal theories to pursue these assets. Existing principles already
applied. Once enforcement tools caught up, regulators simply followed the value.
The most surprised organizations were often those that never considered themselves
“holders” at all.

From 2030, the rule is simple: if value belongs to someone else and you control it, it will
eventually be regulated.

Mistake #3: Treating Unclaimed Property as a Once-a-Year Accounting Exercise

In 2025, unclaimed property often lived in spreadsheets, handled annually by accounting
or tax teams with limited operational insight. That model collapsed under audit scrutiny.

Auditors increasingly asked operational questions:

• How is owner activity defined?
• How is dormancy tracked across systems?
• How is due diligence triggered, documented, and retained?
• How is consistency ensured year over year?

Annual processes could not answer continuous questions. By the late 2020s, successful
organizations had shifted to always-on compliance, where dormancy tracking, owner
outreach, and documentation were part of daily operations.

The deeper lesson from 2030: unclaimed property stopped being a filing obligation and
became a process discipline.

Mistake #4: Underestimating the Role of Data Quality
Late-2020s audits were not decided by legal interpretation alone. They were decided by
data.

In 2025, address histories were overwritten. Account identifiers changed without
traceability. Activity timestamps were ambiguous. System migrations lost context. When
auditors could not reconcile data, they estimated—and estimates favored the state.

Organizations that invested early in master data management, immutable logs, and
historical snapshots were able to defend themselves. Those that relied on “current-state”
data paid a steep price.

From 2030, the lesson is unforgiving: weak data invites estimation, and estimation
multiplies liability.

Mistake #5: Allowing Legacy Systems to Define Compliance Boundaries

Most systems in use in 2025 were never designed to track dormancy, preserve historical
account states, or log owner outreach. Rather than modernize, many organizations layered
manual workarounds onto brittle platforms.

Those workarounds held—until audits demanded scale, consistency, and proof.
By the late 2020s, states no longer accepted system limitations as excuses. Compliance
expectations followed capability, not legacy constraints.

From 2030, the message is blunt: technology debt eventually becomes compliance
debt.

Mistake #6: Designing Products That Held Value Without Compliance in Mind

One of the most expensive failures of 2025 occurred far from accounting departments—
inside product and engineering teams.

Value-holding features were launched quickly: credits, wallets, refunds, promotional
balances, marketplace payouts. Rarely were inactivity rules, owner notifications, reclaim
paths, or retention standards defined upfront.

Years later, finance teams discovered large pools of dormant value with no defensible
compliance framework. The risk had been embedded at launch.

From 2030, organizations learned that unclaimed property risk is often designed into
products, not discovered in reports.

Mistake #7: Failing to Establish Clear Organizational Ownership

In many organizations, unclaimed property belonged to everyone—and therefore to no one.

Payroll managed checks. AP managed vendors. Product owned balances. Customer
service touched accounts. Legal advised occasionally. No one coordinated the whole.

Auditors noticed.

By the late 2020s, enforcement increasingly evaluated governance structures: ownership,
escalation paths, documented decisions, and cross-functional controls.

From 2030, the insight is simple: auditors trust organizations that know who is
responsible.

Mistake #8: Treating M&A and Structural Change as Compliance-Neutral

Acquisitions, divestitures, system migrations, and entity reorganizations were among the
most costly blind spots of the era.

Organizations bought growth—and inherited years of noncompliance without inheriting the
records to defend it. Dormancy logic changed. Filing histories fragmented. Successor
liability arrived quietly, then all at once.

By 2030, experienced acquirers treated unclaimed property like tax or environmental
exposure: performed due diligence early, priced into deals, and addressed post-close.

The lesson: if you buy the balance sheet, you buy its abandoned value too.

Mistake #9: Ignoring Owner Experience and Public Trust

For years, escheatment was treated as inevitable. Few organizations invested in preventing
abandonment or making reclaiming simple.

By the late 2020s, regulators reframed unclaimed property as consumer protection. Media
scrutiny followed. Companies with opaque processes and weak outreach faced
reputational damage alongside financial penalties.

Ironically, organizations that helped owners reclaim value early often reduced regulatory
exposure later.

Mistake #10: Failing to Quantify Risk at the Executive Level

Perhaps the most damaging mistake was invisibility. Unclaimed property rarely appeared in
enterprise risk assessments, forecasts, or board discussions.

When audits hit, leadership was surprised—by scope, cost, and attention.

Organizations that modeled exposure, set reserves, and prepared audit response
strategies navigated enforcement deliberately. Those that did not reacted under pressure.

From 2030, the rule is clear: risks that are not quantified are never prioritized.

What to Prepare for Now (Before the Future Arrives)

From the vantage point of 2030, the organizations that navigated this reckoning best did not
rely on incremental fixes. They took decisive, enterprise-wide action that addressed the
structural weaknesses exposed by enforcement.

They established clear governance, assigning unclaimed property to a named executive
owner with authority across finance, legal, tax, accounting, IT, product, payroll, and
customer operations.

They treated unclaimed property as a continuous operational process, embedding
dormancy tracking, owner outreach, and documentation into daily workflows rather than
annual cleanups

They invested in data integrity and historical traceability, preserving address histories,
activity logs, and account states in audit-ready form.

They modernized systems with compliance in mind, ensuring technology could support
dormancy logic, due diligence triggers, and long-term retention across asset types.

They expanded their definition of risk, inventorying all forms of value—cash and non-cash
alike—as potential unclaimed property.

They embedded compliance into product design, requiring inactivity rules, reclaim paths,
and communication standards before launching value-holding features.

They integrated unclaimed property into M&A and structural change, due diligence
exposure early and planning remediation deliberately.

They addressed historical exposure proactively, using internal lookbacks and voluntary
disclosure agreements to control scope and penalties.

They improved owner experience, reduced abandonment and aligned compliance with
consumer trust.

They quantified financial and reputational risk at the executive level, integrating
unclaimed property into enterprise risk management.

And finally, they leveraged AI thoughtfully—as a decision-support tool for analysis,
reconciliation, and audit readiness—without surrendering human judgment or
accountability.

A Final Word From the Future

The organizations that struggled after 2025 were not reckless. They were operating under
assumptions that no longer held.

Those that thrived recognized unclaimed property for what it had become: a mirror
reflecting how well an organization understands its data, systems, products, and
responsibilities to others’ value.

From 2030, one truth endures:

Where value accumulates, regulation follows. Where records weaken, enforcement
accelerates.

If you are reading this before that reality fully arrives, you still have time—not to react, but
to prepare.

About the Author

Josiah S. Osibodu, CPA, CFE, is an unclaimed property and AI consultant with over 30 years
of experience across Deloitte, Ernst & Young, and Thomson Reuters.

As an AI Consultant, Josiah advises organizations on responsible, AI-driven approaches to
unclaimed property compliance, audit risk assessment, and operational efficiency.

To discuss your organization’s unclaimed property risk or AI integration strategy:
info@moyerosibodu.com; info@jsoconsultingservices.ai; or info@moyerosibodu.ai