{
    "name": "Amundi ShortDAX Daily (-2x) Inverse UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": true,
    "derivatives": true,
    "swaps": true,
    "inverse": true,
    "replication_method": "synthetic",
    "complex_factors": [
        "Leverage (-2x)",
        "Inverse exposure",
        "Synthetic replication via swaps",
        "Counterparty risk from OTC derivatives",
        "Complex benchmark tracking (daily rebalancing)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via unfunded swaps to achieve a -2x inverse daily leverage on the DAX index, which introduces significant complexity through daily rebalancing effects, counterparty risk from swap agreements (with Morgan Stanley and Societe Generale), and the potential for compounding losses. The KIID explicitly warns about the risks of leverage, derivative instruments, and tracking error due to the daily rebalancing mechanism. The factsheet confirms the use of OTC swaps and highlights the risks associated with the inverse leveraged strategy, including the potential for performance divergence from the underlying index over longer periods. The SRRI risk rating of 7 further supports the complex classification.",
    "confidence": 95,
    "counter_argument": "The ETF is UCITS-compliant and provides daily liquidity, which might suggest it is non-complex. However, the leverage, inverse exposure, and synthetic replication via swaps override these factors under MiFID II rules, as these features require specialized knowledge to understand the risks and performance behavior.",
    "risk_level": 7
}