{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi MSCI Eastern Europe Ex Russia UCITS ETF Acc",
    "investment_objective": "Track the MSCI EM Eastern Europe ex Russia Net Total Return index via indirect replication using OTC swap contracts",
    "primary_asset_class": "Equity",
    "geographic_focus": "Emerging Markets countries in Eastern Europe excluding Russia",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via OTC total return swaps",
        "Counterparty risk exposure",
        "Use of financial derivative instruments (FDI)",
        "Emerging markets equity exposure with potential liquidity risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication through OTC swap contracts (financial derivative instruments) with counterparties such as Morgan Stanley Bank AG and Societe Generale, exposing investors to counterparty risk. The fund invests in a diversified portfolio of international equities but achieves index exposure synthetically via swaps, not physical replication. The KIID and PRIIPs KID explicitly mention counterparty risk, derivative risks including leverage risk, valuation risk, and liquidity risk. The fund is UCITS compliant but the synthetic replication and swap usage are key complexity drivers under MiFID II. There is no leverage or inverse exposure, and no capital protection features. The risk rating is 5/7, indicating medium-high risk, consistent with complexity due to derivative and counterparty risk. The factsheet confirms synthetic replication and counterparty exposure capped at 10% of fund assets. No performance fees or complex fee structures beyond a 0.50% ongoing charge are present. The underlying index is an emerging markets equity index excluding Russia, which may have some complexity but is not inherently complex structured products. Overall, the synthetic replication via swaps and associated counterparty risk mandate classification as complex under MiFID II."
}