{
    "fund_name": "Amundi MSCI New Energy ESG Screened UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the MSCI ACWI IMI New Energy ESG Filtered Net Total Return Index, with no evidence of synthetic replication, leverage, or complex derivative usage. The KIID explicitly states the fund uses 'direct replication' and may employ sampling techniques, which are standard for non-complex ETFs. The risk profile (SRRI 6) is typical for equity ETFs and does not indicate complexity. There are no mentions of swaps, unfunded derivatives, or capital protection mechanisms. The factsheet confirms physical replication and UCITS compliance, with no additional complexity indicators. The ESG screening, while adding a thematic layer, does not introduce structural complexity under MiFID II rules.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "Some might argue that the ESG screening methodology or the thematic nature of the index (new energy) could introduce complexity. However, under MiFID II, thematic indices or ESG criteria alone do not classify an ETF as complex unless they involve derivatives, leverage, or illiquid assets. The fund's physical replication and transparent structure override this concern.",
    "additional_notes": "The PRIIPs KID was not provided, but the KIID and factsheet contain sufficient information to confirm the non-complex classification. The absence of any 'comprehension warning' in the available documents further supports this assessment."
}