{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Counterparty Risk",
            "Securities Financing Transactions"
        ],
        "classification": "complex",
        "supporting_data": "The AMUNDI DOW JONES INDUSTRIAL AVERAGE UCITS ETF employs indirect replication using over-the-counter (OTC) swaps to replicate the benchmark index. This reliance on financial derivative instruments (FDIs) introduces counterparty risk, as outlined in the Risk and Reward Profile section, which states that the Fund is exposed to the risk of insolvency or default of any counterparty. Furthermore, the KIID explicitly mentions 'Risk related to the use of derivative instruments' and notes that 'The Fund may use financial contracts that involve different types of risk, such as leverage risks, risks related to high volatility, valuation risk or liquidity risk.' While the ETF is a UCITS, which generally benefits from a non-complex presumption, the extensive use of OTC swaps for replication fundamentally alters its nature. MiFID II guidelines and ESMA documentation (specifically CESR/09-295 and ESMA35-36-1640) consistently flag instruments that are integral to achieving their objective via derivatives, particularly those involving swaps, as complex due to the inherent opacity and counterparty risks not easily understood by retail investors. The KIID also lists 'Counterparty risk' as a particular risk, reinforcing the complexity. The use of swaps means the ETF's assets are not directly held in the index constituents, making its performance dependent on the derivative provider, a concept that adds complexity for retail investors. Therefore, despite tracking a well-known index, the synthetic replication method using OTC swaps leads to a classification of complex."
    }
}