{
    "fund_name": "Amundi MSCI EMU UCITS ETF Dist",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "OTC Swaps with counterparties"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication to track the MSCI EMU Net Return Index, which would typically classify it as non-complex. However, the factsheet reveals the use of OTC swaps with counterparties (Morgan Stanley Bank AG and Societe Generale), which introduces counterparty risk and complexity. While the exposure is limited to 10% of total fund assets under UCITS guidelines, the presence of these swapseven if used for optimization rather than leveragetriggers complexity under MiFID II due to the additional risks and the need for investors to understand counterparty risk. The fund's risk profile (SRRI 5) and the mention of counterparty risk in the KIID further support this classification.",
    "confidence": 85,
    "risk_level": 5,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "capital_protection": false,
    "structured_features": false,
    "underlying_asset_complexity": false,
    "benchmark_complexity": false,
    "additional_notes": "The ETF's use of OTC swaps, though limited and disclosed, introduces an element of complexity that requires investors to assess counterparty risk. While the fund is physically replicated and UCITS-compliant, the swapseven if used for optimizationpush it into the 'complex' category under MiFID II. The absence of leverage or inverse strategies does not override the complexity introduced by derivative instruments with counterparty exposure."
}