{
    "fund_name": "Amundi Dow Jones Industrial Average UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via over-the-counter swaps (OTC swaps) with counterparties such as Morgan Stanley Bank AG and Societe Generale, exposing investors to counterparty risk. The KIID explicitly mentions the use of financial derivative instruments (FDIs) and highlights counterparty risk as a significant factor. The SRRI risk level is moderate, but the presence of swaps and the associated counterparty risk make it complex under MiFID II. The factsheet confirms the synthetic replication method and the use of swaps, reinforcing the complexity classification.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and tracks a well-known, straightforward equity index (Dow Jones Industrial Average). The risk level is moderate, and the derivatives are used for replication rather than leverage or speculative purposes. However, the use of swaps and the explicit mention of counterparty risk in the KIID and factsheet override this argument, as MiFID II considers synthetic replication via swaps a complexity factor due to the additional risks involved.",
    "risk_level": "moderate",
    "primary_reasoning": "The primary factor driving the complexity classification is the use of synthetic replication via swaps, which introduces counterparty risk and requires a deeper understanding of derivative instruments and their associated risks."
}