{
    "name": "AMUNDI MSCI Emerging Markets III UCITS ETF USD Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Derivative Instruments"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to track the MSCI Emerging Markets Net Total Return Index. The KIID explicitly mentions the use of financial derivative instruments (FDIs) and over-the-counter total return swaps, which introduces counterparty risk. The presence of swap agreements and derivative instruments, along with the associated counterparty risk, are key indicators of complexity under MiFID II. Additionally, the risk profile includes warnings about derivative-related risks and liquidity risks, further supporting the classification as a complex instrument.",
    "confidence": 95,
    "risk_level": 5,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "benchmark_complexity": "moderate",
    "additional_notes": "While the ETF is UCITS compliant and aims to track a well-known index, the use of synthetic replication via swaps and the associated counterparty risks make it a complex product under MiFID II. The fact that the ETF is designed for investors with a longer-term horizon (5 years) also suggests it may not be suitable for all retail investors without proper understanding of the risks involved."
}