{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Use of currency forwards and interest rate swaps for hedging",
        "Counterparty risk exposure",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The Amundi Smart Overnight Return UCITS ETF USD Hedged Acc uses an indirect replication method involving financial derivative instruments, specifically total return swaps, currency forwards, currency swaps, and interest rate swaps. These derivatives are integral to achieving the fund's investment objective, not merely for risk management, indicating inherent complexity. The KIID explicitly mentions counterparty risk and collateral arrangements to mitigate this risk, highlighting exposure to derivative counterparty risk. The fund is UCITS compliant but employs synthetic replication rather than physical replication. There is no leverage or inverse exposure, and the risk indicator is low (1 out of 7), reflecting low market risk but not negating complexity due to derivative usage. The PRIIPs KID confirms the use of swaps and hedging strategies, and the factsheet confirms synthetic replication and swap usage. The presence of total return swaps and other derivatives as a core part of the investment strategy, combined with counterparty risk, classifies this ETF as complex under MiFID II. The fund does not use leverage or capital protection features, and the risk profile is low, but the synthetic replication and swap usage are determinative for complexity classification."
}