{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi MSCI Turkey UCITS ETF Acc",
    "investment_objective": "Track the MSCI Turkey Net Total Return Index via indirect replication using OTC swap contracts",
    "primary_asset_class": "Equity",
    "geographic_focus": "Turkey",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via OTC total return swaps",
        "Counterparty risk exposure",
        "Emerging market equity exposure",
        "Use of derivatives as inherent part of strategy"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through OTC swap contracts with counterparties such as Morgan Stanley Bank AG and Societe Generale, as explicitly stated in the KIID and factsheet. The fund invests in international equities but achieves index exposure via total return swaps, which introduces counterparty risk and derivative-related risks. The risk indicator is high (6/7), reflecting significant market and counterparty risks. There is no leverage or inverse exposure, but the use of swaps as a core part of the replication method classifies the ETF as complex under MiFID II. The fund is UCITS compliant but the synthetic structure and derivative use mean the product is not straightforward for retail investors to understand. The underlying index is an emerging market equity index (MSCI Turkey), which adds to complexity due to market volatility and liquidity risks. Costs are straightforward with no performance fees, but swap fees and counterparty risk disclosures are present. No capital protection or structured features are identified. The PRIIPs KID does not carry a specific comprehension warning but confirms the high risk and derivative use. Overall, the synthetic replication and swap usage are the main drivers of complexity classification."
}