of Elizabeth in some common law jurisdictions has no statute of limitations), the general statute of limitations in the Cook Islands is reduced to two years for fraudulent transfers; in certain circumstances, it may be as short as one year. If the trust is funded while the settlor is solvent, then the transfer cannot be challenged.(i.e., there is no time period for the creditor to challenge the transfer) Several provisions of the Cook Islands law specify the form of pleading that a creditor must establish in order for its claim to be heard in a Cook Islands court. The effect of these provisions is to raise the burden of proof to "beyond a reasonable doubt," something akin to a criminal law standard, in order for a creditor to establish a fraudulent transfer. The "constructive" fraudulent transfer theories are eliminated under Cook Islands law, requiring the creditor to prove that the transfer was made with specific intent to avoid the creditor's claim. It is believed that the Cook Islands now has more registered asset protection trusts than any other country, although in most jurisdictions a Trust is considered a private arrangement and it is not a requirement to register a Trust. Case law is somewhat lacking in the Cook Islands. However, some landmark decisions show that the Cook Islands Court intends to uphold the asset protection trust law. In 1999, the Federal Trade Commission attempted to recover assets from a Cook Islands Trust. The suit filed by the FTC against a trust company was unsuccessful. The quality of the judiciary and the associated banking and investment services offered from the Cook Islands are considered poor. Nevis Nevis was one of the first countries to follow the Cook Islands, duplicating an older version of the Cook Islands law and naming it the Nevis International Exempt Trust Ordinance, 1994. One distinguishing feature of the Nevis legislation is that a creditor must post a bond of ECB 25,000 (roughly USD 13,000) to lodge a complaint against a trust registered in Nevis. Very little case law exists in Nevis, which many attorneys interpret to mean that creditors are effectively deterred from bringing suit in Nevis. It has a small offshore banking industry, with St. Kitts-Nevis-Anguilla Bank and Bank of Nevis International as the only licensed offshore banks. LLC legislation modeled after the Delaware LLC Act was passed in 1996. This has enabled Nevis to distinguish