{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The Amundi FTSE 100 UCITS ETF Acc employs synthetic replication using an over-the-counter (OTC) swap contract to track the FTSE 100 Total Return Index. This use of derivatives, specifically swaps, to achieve its investment objective is a primary driver for classifying this ETF as complex under MiFID II. The KIID explicitly mentions 'Counterparty risk' and 'Risk of Financial derivative Instruments' as key risks, which are inherently difficult for retail investors to fully understand. The rationale for complexity stems from the risks associated with the counterparty to the swap and the mechanics of derivative replication, which are not as transparent as physical replication. Even though it is a UCITS ETF, the synthetic replication method with its inherent derivative usage and associated risks overrides the general presumption of non-complexity."
    }
}