{
    "success": true,
    "data": {
        "complex": false,
        "leverage": false,
        "derivates": false,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Indirect Replication via Swaps",
            "Potential for Tracking Error"
        ],
        "classification": "complex",
        "supporting_data": "The Amundi Pan Africa UCITS ETF utilizes indirect replication by entering into an over-the-counter swap contract (a financial derivative instrument) to track the SGI Pan Africa Net Total Return index.  While the fund is a UCITS ETF, and therefore generally presumed non-complex due to regulatory requirements, the reliance on swaps introduces complexity.  The use of a financial derivative (swap) to replicate the index introduces counterparty risk.  This is a key element that makes the fund complex for MiFID II classification.  While the swap is collateralized, and the fund may invest in a diversified portfolio of international equities, these features are not enough to negate the fundamental complexity introduced by the derivative-based strategy. The fund's reliance on a financial derivative is a primary characteristic of a complex structure. The use of swaps introduces a complexity factor exceeding the threshold for an easy understanding for the average retail investor by introducing counterparty risk and collateral risk, despite well-managed structures. "
    }
}