{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi MSCI AC Asia Ex Japan UCITS ETF Acc",
    "investment_objective": "Track both upward and downward evolution of the MSCI AC Asia ex Japan Net Total Return Index via indirect replication using OTC swap contracts.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Asia ex Japan (including China, Hong Kong, India, Indonesia, Korea, Malaysia, Philippines, Singapore, Taiwan, Thailand)",
    "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 derivatives as inherent part of strategy",
        "Emerging markets exposure with potential liquidity and volatility risks"
    ],
    "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 capped at 10% of fund assets. The fund invests in a diversified portfolio of international equities but achieves index exposure synthetically via swaps rather than physical replication. The risk disclosures highlight derivative-related risks including leverage risk, valuation risk, liquidity risk, and counterparty risk. The fund is UCITS compliant but the synthetic replication and swap usage inherently increase complexity under MiFID II. There is no leverage or inverse exposure, but the use of total return swaps as a core replication method classifies the ETF as complex. The risk rating is medium (4/7), reflecting market and derivative risks but not excessive leverage. The underlying index covers emerging markets with inherent volatility and liquidity considerations. No capital protection or structured features are present. Costs are straightforward with no performance fees but include swap-related costs embedded in ongoing charges. The PRIIPs KID does not carry a specific comprehension warning but confirms the synthetic replication and counterparty risk. The factsheet confirms synthetic replication, counterparty risk exposure, and no leverage. Overall, the synthetic replication via swaps and associated counterparty risk are the main drivers of complexity classification under MiFID II."
}