{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Emerging/frontier market focus"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to achieve exposure to the MSCI Africa Top 50 Capped TRN index, which is a key complexity indicator under MiFID II. The KIID explicitly states the fund enters into financial contracts (derivatives) with counterparties, creating counterparty risk. The index itself includes frontier and emerging markets, adding to the complexity. While there is no leverage or inverse exposure, the use of swaps for replication (rather than physical holding of securities) and the emerging/frontier market focus make this a complex product. The risk profile (category 6) and extensive derivative-related disclosures further support this classification. The PRIIPs KID and factsheet confirm the swap-based structure and counterparty risk, reinforcing the complexity determination.",
    "confidence": 90
}