{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi Euro Government Bond 15+Y UCITS ETF Acc",
    "investment_objective": "Track Bloomberg Barclays Euro Treasury 50bn 15+ Year Bond Index via direct replication or sampling",
    "primary_asset_class": "Bond",
    "geographic_focus": "Eurozone sovereign bonds",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC swaps for securities lending counterparty risk, complex underlying sovereign bond index with long duration",
    "classification": "complex",
    "supporting_data": "The ETF is a UCITS fund physically replicating the Bloomberg Barclays Euro Treasury 15+ Year Bond Index primarily by direct purchase of underlying bonds, with possible sampling. The KIID and factsheet confirm physical replication but also disclose counterparty risk from OTC swaps used in securities lending programs with Morgan Stanley and Societe Generale, with counterparty exposure capped at 10%. There is no leverage or inverse exposure. The underlying assets are long-dated Eurozone sovereign bonds, which are liquid but have interest rate and credit risk. The risk rating is medium (4/7). The use of OTC swaps for securities lending introduces counterparty risk and derivative exposure inherent to the fund's operation, not just risk management. According to MiFID II criteria, any swap usage triggers complexity classification. The fund does not use leverage or structured capital protection. Costs are straightforward with no performance fees. The PRIIPs KID does not include a comprehension warning but notes liquidity and market risks. Overall, the presence of OTC swaps and counterparty risk, combined with the complexity of the long-duration sovereign bond index, leads to a classification of complex under MiFID II despite physical replication and moderate risk profile."
}