Section 1.5
The international market at a glance
Essential question
Structured products issued in Hong Kong, Frankfurt and New York carry the same name. Why are they in practice 3 different products answering 3 incompatible market logics?
Switzerland is not alone. Three major structured products hubs coexist worldwide, each with its own signature: dominant products, a regulator, a client profile. Understanding these differences is essential for a manager structuring for an international client base or comparing offers across venues.
The three markets are not measured with the same yardstick. Switzerland and Germany publish statistics on issued volumes and outstandings (SSPA, DDV). Asia (Hong Kong, Singapore, South Korea) speaks rather in notes outstanding, with no consolidated aggregate. The USA has no official “structured products” category — the notes appear in SIFMA's structured notes segment. Comparing in absolute value is misleading; better to compare by dominant profile.
Before the table — your intuition
Which regulator for which market?
Which main regulator supervises structured products sold to retail investors in (1) continental Europe (2) Asia (3) the USA? And which type of product do you think dominates in each region?
Europe · Asia · USA comparison
Germany + France + Italy + Switzerland in the lead
Hong Kong + Korea + Singapore + Japan
Concentrated institutional market
Capital protection
DDV (Germany): ~50% Express
Accumulators
HK retail: massive on 2-3 year tenors
Market-Linked CDs
Mostly HNW + institutional
PRIIPs KID, MiFID II, EU prospectus
Local regimes, sometimes strict suitability tests (post-2008)
Securities Act 1933, FINRA Rule 2111 suitability
Sources: SSPA Industry Report Q4 2025, DDV Statistik Q4 2025, SIFMA Structured Notes Annual 2024, Asifma Asia Structured Products Survey 2024. Estimated outstandings — no consolidated global figures exist.
Case study · global client
A Swiss manager structures for a Hong Kong client who wants an autocall on Tesla.
Which issuer + venue combination best matches Swiss private banking practice for this client profile?
Key message
The three hubs (Europe / Asia / USA) are not interchangeable: each market has its regulator, its dominant products, its client profile. The right reflex when structuring for a global client from Switzerland is to structure at home (issuer on SIX) — unless there is an explicit operational reason (local custody, different dominant currency).
A few key figures to remember: Europe ~EUR 400 bn outstanding, Asia ~USD 300 bn, USA ~USD 150 bn. Switzerland alone weighs ~CHF 250 bn — about 60% of the European market. This concentration is what makes the Swiss venue unavoidable for the international UHNW client base.
EUSIPA (European Structured Investment Products Association) brings together the 9 European national associations (SSPA included) and publishes a harmonised categorisation — the Swiss Derivative Map © is compatible with the EUSIPA Derivative Map. For comparisons across venues, it is the reference standard.
Question 1 / 3
What is the dominant product in the German structured products market?
Question 2 / 3
The US structured products market is essentially sold to:
Question 3 / 3
If a Swiss manager wants to compare a German issue and a Swiss issue on the same payoff, which common reference should be used?