{
    "fund_name": "Amundi MSCI EMU UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Derivative Usage for Optimization"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but acknowledges the use of swaps with counterparties (Morgan Stanley Bank AG, Societe Generale) for optimization purposes. While the replication method is physical, the presence of unfunded swaps introduces counterparty risk and derivative exposure, which are key complexity indicators under MiFID II. The factsheet explicitly mentions 'counterparty risk resulting from the use of an OTC Swap,' which, despite being within UCITS limits (=10% exposure), still qualifies the instrument as complex due to the additional risks involved. The KIID does not disclose leverage or inverse strategies, but the derivative usage for purposes beyond simple replication (e.g., optimization) and the explicit counterparty risk warnings justify the 'complex' classification.",
    "confidence": 0.85,
    "risk_level": "The SRRI risk level is 4, indicating moderate risk, but the derivative and counterparty risks elevate the complexity.",
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication and straightforward equity exposure. However, the explicit mention of swap agreements and counterparty risk in the factsheet overrides this argument, as MiFID II considers even limited derivative usage for non-replication purposes as a complexity factor."
}