{
    "name": "Amundi Pan Africa UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Emerging market complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an OTC swap contract with counterparties (Morgan Stanley Bank AG and Societe Generale), which introduces counterparty risk and complexity. The KIID explicitly mentions 'Financial Derivative Instruments' and associated risks like leverage, high volatility, and liquidity risks. The factsheet confirms the synthetic replication method and highlights counterparty risks. While the ETF does not use leverage or inverse strategies, the reliance on swaps and exposure to emerging markets (which are inherently more complex) make it a complex instrument under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "benchmark_complexity": "The SGI Pan Africa Index includes equities from emerging markets, which are inherently more volatile and less liquid, adding to the complexity.",
    "liquidity_risk": true,
    "comprehension_warning": "The PRIIPs KID (if available) might include a comprehension warning due to the synthetic replication and emerging market exposure, reinforcing the complex classification."
}