{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Counterparty risk stemming from over-the-counter (OTC) derivative instruments.",
            "Potential use of derivative instruments for efficient portfolio management (EPM) that introduces counterparty risk, making the product's risk profile less straightforward for a retail investor."
        ],
        "classification": "complex",
        "supporting_data": "The Amundi FTSE MIB UCITS ETF Dist is a UCITS compliant, physically replicated ETF that tracks the FTSE MIB Net Total Return Index. While UCITS ETFs are generally presumed non-complex and physical replication is straightforward, the Key Investor Information Document explicitly states the presence of 'Counterparty risk' arising from 'financial derivative instruments traded over the counter or securities delivered under securities financing transactions'. The provided MiFID II complexity assessment rules and ESMA guidance highlight that the use of derivatives, even for EPM, can lead to a complex classification if it introduces risks like counterparty risk that are difficult for retail investors to understand. The instruction specifically mandates a 'complex' classification if any swap usage or similar complex derivative element (like OTC derivatives) is identified, as these introduce risks beyond basic financial literacy. Therefore, despite its physical replication method and UCITS status, the explicit mention of counterparty risk due to OTC derivative instruments necessitates a 'complex' classification."
    }
}