{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi MSCI China UCITS ETF Acc",
    "investment_objective": "Track the MSCI China Net Total Return USD Index via indirect replication using OTC swap contracts",
    "primary_asset_class": "Equity",
    "geographic_focus": "China",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic replication",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication via over-the-counter swap contracts (financial derivative instruments) to achieve its investment objective, as explicitly stated in both the KIID and PRIIPs KID. The fund invests in a diversified portfolio of international equities and enters into swap agreements to exchange performance with the MSCI China Net Total Return USD Index. The factsheet confirms the synthetic replication method and identifies counterparty risk exposure to Morgan Stanley Bank AG and Societe Generale, with counterparty exposure limited to 10% of total assets. There is no leverage or inverse exposure. The fund is UCITS compliant. The risk profile is medium-high (5/7), reflecting market risk and derivative-related risks including leverage risk, valuation risk, and liquidity risk. Costs are straightforward with no performance fees but include ongoing charges of 0.29%. The use of swaps and synthetic replication, combined with counterparty risk and derivative exposure, triggers the MiFID II classification as complex, despite the absence of leverage or capital protection features. The underlying index is a broad China equity index, which is not inherently complex, but the synthetic structure and counterparty risk increase complexity. No capital protection or structured features are present. The PRIIPs KID does not include a comprehension warning but confirms the medium-high risk and derivative usage. Overall, the key complexity drivers are the synthetic replication via OTC swaps and associated counterparty risk.",
    "risk_level_assessment": "The fund's stated risk level is 5 out of 7 (medium-high), consistent with the presence of derivative instruments and counterparty risk. This aligns with the MiFID II complexity classification, as the use of swaps and synthetic replication increases the risk and complexity beyond a straightforward physical replication ETF."
}