{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Amundi Nasdaq-100 II UCITS ETF Acc",
    "investment_objective": "Track both upward and downward evolution of NASDAQ-100 Notional Net Total Return Index via indirect replication using OTC swap",
    "primary_asset_class": "Equity",
    "geographic_focus": "United States (100%)",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Swaps",
        "Synthetic replication",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses indirect replication via an over-the-counter swap contract (financial derivative instrument) to achieve its investment objective, as explicitly stated in both the KIID and PRIIPs KID. The replication method is synthetic, confirmed by the factsheet. The fund invests in a diversified portfolio of international equities but exchanges performance via the swap, indicating derivative use is inherent to the strategy, not just for risk management. Counterparty risk is explicitly disclosed, with counterparties including Morgan Stanley Bank AG and Societe Generale, with exposure capped at 10% of total assets. The risk profile is medium-high (5/7), reflecting market and derivative risks. There is no leverage or inverse exposure. The underlying assets are large-cap US equities, which are liquid and transparent, but the synthetic swap structure and counterparty exposure introduce complexity. Costs are straightforward with no performance fees, but swap usage implies derivative costs. No capital protection or structured features are present. The PRIIPs KID does not carry a specific comprehension warning but the synthetic swap structure and counterparty risk are complexity drivers under MiFID II. Therefore, despite a straightforward equity index objective, the use of funded/unfunded swaps and counterparty risk classifies this ETF as complex under MiFID II rules."
}