{
    "type": "ETF",
    "ucits": true,
    "fund_name": "AMUNDI MSCI Emerging Markets III UCITS ETF EUR Acc",
    "investment_objective": "Replicate the USD-denominated MSCI Emerging Markets Net Total Return Index using indirect replication via OTC total return swaps.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Emerging Markets",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via OTC total return swaps",
        "Counterparty risk exposure",
        "Emerging markets equity exposure",
        "Use of derivatives inherent to strategy (swaps)",
        "Potential liquidity risk due to emerging markets and OTC instruments"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through OTC total return swaps with counterparties such as Morgan Stanley and Societe Generale, explicitly stated in the KIID and PRIIPs KID. The Fund invests in a diversified portfolio of international equities but does not physically hold the underlying index securities. The use of swaps is an inherent part of the investment strategy, not merely for risk management, which triggers complexity classification under MiFID II. The Fund carries counterparty risk limited to 10% per counterparty, but this risk is significant and disclosed. The risk profile is medium (4/7), reflecting market and derivative risks. There is no leverage or inverse exposure. The underlying index is a broad emerging markets equity index, which can be volatile and less liquid than developed markets. Costs are straightforward with no performance fees, but swap-related costs are implicit. The PRIIPs KID does not include a specific comprehension warning but highlights counterparty and liquidity risks. The factsheet confirms synthetic replication and counterparty exposure, reinforcing the complexity classification. Overall, the synthetic replication via swaps and counterparty risk are the main drivers of complexity despite the fund being UCITS compliant and having a medium risk profile."
}