{
    "type": "ETF",
    "ucits": true,
    "fund_name": "AMUNDI MSCI EUROPE MOMENTUM FACTOR UCITS ETF - EUR",
    "investment_objective": "Track the performance of MSCI Europe Momentum Index with minimized tracking error",
    "primary_asset_class": "Equity",
    "geographic_focus": "European developed countries",
    "replication_method": "synthethic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses an indirect replication methodology via a total return swap (financial derivative instrument) to achieve exposure to the MSCI Europe Momentum Index. The KIID and PRIIPs KID explicitly state that derivatives are integral to the investment strategy, with counterparty risk disclosed as a material risk. The replication method is synthetic, confirmed by the factsheet. There is no leverage or inverse exposure. The underlying assets are equities from European developed markets, which are liquid and transparent. The risk profile is medium (4/7), reflecting market and counterparty risks. Costs are straightforward with no performance fees, but swap usage implies derivative costs. The presence of total return swaps and counterparty risk exposure mandates classification as complex under MiFID II, despite the fund being UCITS compliant and having a moderate risk profile. No capital protection or structured features are present. The complexity arises primarily from the synthetic replication via swaps and associated counterparty risk, which may reduce retail investors' ability to easily understand the product. No leverage or contingent bonds are involved. No PRIIPs comprehension warnings were noted. Overall, the synthetic replication and swap usage are the key drivers of complexity classification."
}