Regulatory Mapping That Regulators Actually Understand

A mid-sized Swiss financial services group — holding a FINMA banking licence and operating across wealth management, asset management, and insurance — faced a recurring challenge that consumed disproportionate resources for its apparent simplicity: producing regulatory structure diagrams that met FINMA's exacting requirements. The Swiss Financial Market Supervisory Authority expected clear, accurate depictions of the group's legal structure, beneficial ownership chains, qualified participations, and intra-group relationships, updated and submitted on a regular basis. For a group with twenty-three entities across Switzerland, Liechtenstein, Luxembourg, and the Cayman Islands, this was no small undertaking.

The group had grown steadily over two decades, principally through acquisitions. A wealth management boutique acquired in 2008. An asset management firm added in 2012. An insurance subsidiary licensed in 2016. Each acquisition brought its own entities, its own regulatory obligations, and its own structural complexity. The result was a corporate group that made perfect commercial sense but whose legal architecture required careful explanation — particularly to a regulator that demanded precision.

The compliance team — a chief compliance officer, two compliance managers, and a regulatory reporting analyst — had been producing the required structure diagrams using a combination of four tools: Microsoft Visio for the diagrams themselves, Excel for the underlying entity data, SharePoint for document storage and version management, and email for coordination with the group's subsidiaries and their local administrators. Each tool served a specific purpose, but together they formed a process that was fragile, slow, and stressful.

The typical workflow for producing a regulatory structure update began with the reporting analyst requesting current entity data from each subsidiary's local administrator. These requests went out by email and were answered at varying speeds — sometimes within days, sometimes not for weeks. The analyst would then reconcile the responses against the master Excel file, update the data, and pass the updated information to one of the compliance managers, who would open the Visio diagram, locate the relevant entities, and make the changes manually. The updated diagram was saved to SharePoint, where the CCO would review it, request corrections, and eventually approve the final version for submission to FINMA.

The process was tolerable for routine annual submissions, where the timeline was measured in weeks. It became acutely painful during regulatory examinations, when FINMA requested updated structure diagrams with turnaround times measured in days. The compliance team would enter what the CCO privately called 'fire drill mode': dropping all other work, chasing subsidiary administrators by phone, updating Visio diagrams late into the evening, and submitting documents that everyone knew were less than perfectly current. The CCO estimated that the team spent roughly forty working days per year on structure diagram production and maintenance — time that could have been devoted to substantive compliance work.

The impetus for change came from an unexpected direction. During a routine FINMA examination in the autumn, the examination team questioned the accuracy of the group's submitted structure diagram. A small but significant error — an intermediate holding entity shown with an incorrect ownership percentage — had survived multiple rounds of internal review. The error was not material in regulatory terms, but it damaged the group's credibility with the examination team and prompted an uncomfortable conversation between the CCO and the group's board. The board asked the compliance team to propose a solution that would prevent similar errors in future.

The CCO had been aware of Juristic Structure through industry contacts — another Swiss financial group had mentioned the platform at a compliance roundtable — but had not considered it seriously until the board's request forced a re-evaluation. She arranged a demonstration for the compliance team and, critically, for the group's head of IT, whose buy-in would be necessary for any new platform. The demonstration was straightforward: the Juristic team imported a sample structure based on publicly available information about the group and showed how it could be maintained, updated, and exported in a fraction of the time the current process required.

Migration to Juristic Structure began the following quarter. The compliance team built the group's regulatory structure in a single workspace, starting with the top-level holding company and working down through the ownership chain to every subsidiary, branch, and representative office. Each entity was tagged with its licence type, regulatory status, supervisory classification, and the responsible local administrator. Beneficial ownership chains were mapped visually, with percentage holdings calculated automatically and displayed on the connecting lines between entities. Qualified participations — holdings above certain thresholds that trigger FINMA notification requirements — were flagged automatically.

The collaborative features proved essential for maintaining the structure going forward. Each subsidiary's local administrator was granted contributor access to the relevant portion of the workspace. When an entity's board changed, or articles of association were amended, or a new branch office was opened, the local administrator updated Structure directly — eliminating the email-based request cycle that had been the previous workflow's weakest link. The compliance team could see these updates in real time and verify them as part of their ongoing monitoring, rather than discovering them weeks later during the next scheduled data collection.

The first test of the new system came during the annual FINMA submission. The compliance team prepared the regulatory structure diagram by reviewing the current state of the Structure workspace — verifying that all updates had been made, that ownership percentages were correct, and that entity classifications matched the latest regulatory guidance — and then exported the diagram as a high-resolution PDF. The entire process, from review to submission, took less than two days. The previous year's submission had taken three weeks.

The FINMA examination team noticed the improvement. During the next examination cycle, the lead examiner commented on the enhanced clarity of the structure diagrams and the ease with which the compliance team could answer questions about specific entities or ownership chains. When the examiner asked about the group's Cayman Islands vehicles and their relationship to the Swiss banking licence, the compliance manager opened Structure on-screen, navigated to the relevant entities, and showed the complete ownership chain from the Cayman fund to the Swiss parent — with every intermediate holding, every percentage, and every regulatory classification visible in a single view. Under the old system, answering the same question would have required cross-referencing the Visio diagram with the Excel data file.

When the group acquired a small Zurich-based asset manager the following year, the integration into the regulatory structure was completed in a single afternoon. The CCO added the acquired entities to the Structure workspace, set the ownership relationships, classified each entity by regulatory status, and generated an updated submission for FINMA's acquisition approval process. No Visio rework. No Excel reconciliation. No email chain to coordinate the change with the design team — there was no longer a design team involved in the process at all.

The reporting analyst, whose previous role had been dominated by data collection emails and spreadsheet maintenance, was retrained to focus on regulatory monitoring and horizon scanning. The CCO describes this reallocation as one of the most significant benefits of the migration: 'We hired that person to think about compliance risk, and we had them spending most of their time chasing emails about entity data. Now they are actually doing the job we hired them to do.'

The group has since expanded its use of Juristic Structure beyond regulatory submissions. The structure workspace is now used as the reference source for board presentations, investor materials, and the group's annual report. The group's external auditors access a read-only view of the workspace during the annual audit, eliminating the back-and-forth of document requests that had previously characterised the audit of group structure. The CFO, who had initially viewed the compliance team's tool adoption with mild indifference, now describes it as one of the group's most valuable operational improvements.

The CCO's summary of the transformation is characteristically Swiss in its understatement: 'We stopped dreading regulatory submissions and started treating them as routine. The structure diagram is no longer something we produce under pressure and hope is correct. It is something we maintain continuously and know is correct. For a regulated institution, that difference is everything.'