{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi MSCI Emerging Ex China UCITS ETF Acc",
    "investment_objective": "Track the MSCI Emerging Markets Ex China Net Total Return Index via indirect replication using OTC swap contracts",
    "primary_asset_class": "Equity",
    "geographic_focus": "Emerging Markets excluding China",
    "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 inherent to replication strategy",
        "Emerging markets equity exposure with potential liquidity risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication through over-the-counter swap contracts (financial derivative instruments) with counterparties such as Morgan Stanley Bank AG and Societe Generale, exposing investors to counterparty risk. The replication is explicitly synthetic, not physical, confirmed by the factsheet. The fund invests in a diversified portfolio of international equities but achieves index exposure via swaps, which is a key complexity driver under MiFID II. There is no leverage or inverse exposure, but the use of swaps and derivatives as an inherent part of the investment strategy classifies the ETF as complex. The risk profile is medium (4/7), reflecting market risk and derivative-related risks including counterparty and liquidity risks. Costs are straightforward with no performance fees, but swap-related risks and counterparty exposure remain significant complexity factors. The underlying index tracks emerging markets ex China equities, which can be volatile and less liquid, adding to complexity. The PRIIPs KID does not include a specific comprehension warning but confirms the use of OTC swaps and counterparty risk. Overall, the synthetic replication and swap usage are the main drivers of complexity classification despite the fund being UCITS compliant and having a moderate risk rating."
}