{
    "success": true,
    "data": {
        "leverage": true,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Synthetic Replication",
            "Swaps (OTC swap contract)",
            "Counterparty Risk",
            "Derivative Risk",
            "Implicit Leverage Risk"
        ],
        "classification": "complex",
        "supporting_data": "The 'Amundi FTSE 100 UCITS ETF USD Hedged Acc' is classified as 'complex' primarily due to its use of 'indirect replication' via 'over-the-counter swap contract' (financial derivative instrument, 'FDI') to achieve its investment objective. This means derivatives are integral to its strategy, not merely for efficient portfolio management (EPM). The rules state that an ETF is complex if derivatives are integral to its objective, such as using swaps for index replication. The KID explicitly highlights 'Counterparty risk' and 'Risk of Financial derivative Instruments', including 'leverage risk', 'high volatility risk', 'valuation risk' or 'liquidity risk', which are inherent to synthetic replication and make the product's structure and payoff difficult for a retail investor with basic knowledge to understand. While the ETF is UCITS compliant, which usually presumes non-complexity, this presumption is explicitly overturned by the significant use of derivatives as a core component of its investment strategy and the associated complex risks. The ESMA guidelines also confirm that structured UCITS or those embedding derivatives can be classified as complex, overriding the general non-complex presumption for UCITS."
    }
}