SRP Digest: Regulation in Focus

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Global markets are navigating a shifting regulatory and product landscape. In Europe, Germany’s financial watchdog has tightened rules on turbo certificates, while the UK’s FCA continues to caution retail investors about CFD risks. Meanwhile, structured product volumes declined slightly across major European markets, even as innovation continued with new thematic and index-linked issuances in France and Poland.

In Asia and the Americas, momentum remains strong. DBS and Goldman Sachs completed their first OTC crypto options trade in Singapore, signaling growing institutional appetite for digital-asset derivatives. South Korea’s DLB market surged past KRW30 trillion, and new cross-border opportunities are emerging under Hong Kong’s Wealth Management Connect scheme. In the US, structured note issuance rose alongside record annuity sales, though legal scrutiny over product suitability continues. Across regions, the industry is balancing innovation with tighter oversight and evolving investor demand.

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This Week's Intel

From Germany’s new rules on turbo certificates, DBS and Goldman’s OTC crypto options trade in Asia to a US large wholesaler being sued over its alleged misrepresentation of structured notes, here’s the weekly roundup brought by SRP news desk.

The German structured products market is adjusting to a stricter regulatory environment for turbo certificates following the release of new product intervention rules by the German Federal Financial Supervisory Authority.

The new circular restricts the marketing, distribution and sale of these leveraged products to retail investors, introducing enhanced risk disclosures and limitations on distributor incentives.

The circular primarily imposes new distribution requirements, including a specific, standardised risk warning - Patrick Scholl, Mayer Brown

Patrick Scholl, capital markets partner at Mayer Brown in Frankfurt, told SRP that the regulator’s intervention “is not a full ban,” however.  He said that the circular primarily imposes new distribution requirements, including a specific, standardised risk warning, and prohibits certain incentives in the retail sales process. Professional investors remain unaffected.

In the UK structured products market, an estimated £126m (US$169m) was collected from 69 publicly offered structured products in September, with volumes dropping over eight percent month-on-month and year-on-year, SRP data shows.

The UK’s Financial Conduct Authority issued a warning to investors about the risks associated with contracts for difference (CFDs), highlighting concerns that some firms are encouraging retail clients to forgo critical consumer protections.

In Poland’s primary market, structured products’ estimated sales were down six percent to PLN1.4 billion (US$390m) in the third quarter of 2025, according to SRP data. The number one provider, Santander, distributed nine products worth an estimated PLN360m – the equivalent of a 25% market share.

In France, Natixis issued a 10-year medium-term note (MTN) on the iEdge N Allemagne Leaders Decrement 50 Points GTR Index, which is equally weighted and tracks the performance of 10 companies listed in Germany with the iEdge Eurozone 300 Index as the initial universe.

In Asia, DBS and Goldman Sachs completed their first-ever over-the-counter (OTC) crypto options trade through trading cash-settled OTC Bitcoin and Ether options.

The Singaporean bank said its clients executed over US$1 billion of trades involving cryptocurrency options and structured notes in the first half of the year, with trade volumes growing 60% from the first quarter to the second quarter of 2025.

Hong Kong-based CMB Wing Lung Bank is planning to include structured deposits in its eligible investment product offering to mainland China investors in the Greater Bay Area through the cross-boundary Wealth Management Connect Scheme’s Southbound channel.

The Hong Kong retail bank is joining China Citic Bank International and Bank of China (Hong Kong), the current local banks distributing principal-protected structured deposits to mainland investors under the scheme.

Also in Hong Kong, the Securities and Futures Commission is proposing to accept the Value-at-Risk approach in the retail fund framework, alongside the existing net derivative exposure limit.

In South Korea, derivative-linked bonds (DLBs), the preferred vehicle for delivering interest-rate exposure with capital protection, saw their outstanding balance cross the KRW30 trillion (US$20.97 billion) mark by the end of the third quarter of 2025, according to the latest figures released by the Korea Securities Depository. By issuance, the sales volume of newly issued DLBs soared 53% year-on-year to around KRW5.79 trillion in the three months ended September.

Looking at the Americas market, First Trust Portfolios has been accused of aiding Vora Wealth Management and Dharmesh Vora in ‘unlawful sale of high-risk structured notes’ to over 100 Arizona retirees which collectively lost US$89m out of their US$124m in principal, according to a class action complaint with jury demand filed on 16 October.

US annuity sales reached a record US$119.3 billion in the third quarter of the year, boosted by registered index-linked annuities, according to preliminary data from Limra’s US Individual Annuity Sales Survey.

In September, a worth of US$15.3 billion in structured notes were issued in the US, up 16% from the prior month, SRP data shows. Over 52% of the monthly structured notes sales volumes came from autocallable structures, of which some come with a digital, reverse convertible or twin win payoff.

Global wealth management platform Arta Finance launched ‘Custom Yield Builder,’ a new functionality in its platform in the US, allowing users to design and fund structured notes for a minimum US$25,000.

BBVA has traded approximately MXN150 billion (US$8.2 billion) in notional of structured products for Mexican investors for the past 12 months. Two thirds of the flow come from dual currency notes with a maturity of seven to 14 days, while the remainder was collected by equity-linked warrants which have doubled their sales volume since 2024.

Meanwhile, the Canadian issuer Desjardins saw the market show signs of “stabilisation after the redemption-driven decline in 2024,” particularly in principal-at-risk (PAR) notes, according to market-linked product manager Dominic Laurin.

This Week's Analysis

Nvidia leads the single stock structure’s early redemption in the region as the US chipmaker's stock rallies.

Over 10,700 autocallables have been early redeemed in the Asia ex-China region this year as far as equities continue to rally, SRP data shows.

Growth autocall remained on the leading front, accounting for around 68% of the estimated sales of overall early redeemed products, while income autocall made up around 26%, according to SRP data as of 24 October.

Some 36% of the early redemption volume came from single-stock autocallable structures, which mostly came from issuances in Hong Kong SAR.

Nvidia led as the top asset being early redeemed across autocall structures. Autocalls on the US chipmaker's stock, which saw the shares soar over 46% year-to-date, accounted for 10% of the knocked-out single stock products’ estimated volume.

Nvidia’s shares jump this year (US$)

Tailing behind were Hong Kong-listed Xiaomi and Alibaba, hovering at around nine percent and eight percent of the redeemed single stock products, respectively, as investors raised hopes on the recovery of some of the Chinese equities this year.

The former Chinese electric vehicle maker saw its stock surge more than 25% this year so far, while the latter tech stock jumped more than 101%, particularly boosted by its artificial intelligence development that pushed its Hong Kong-listed stock to a nearly four year high last month.

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• Market fundamentals remain dominant – 75% see economic and financial conditions as the key driver into 2026. Investor demand, regulation and technology are important but secondary.
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• AI tipped as the next game changer – Nearly 40% identify AI as the most transformative technology, expected to reshape structuring, pricing and distribution.
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