{
    "fund_name": "Amundi Euro Government Bond 1-3Y UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "OTC Swaps with counterparties",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication to track the Bloomberg Barclays Euro Treasury 50bn 1-3 Year Bond Index. However, the factsheet reveals the use of OTC swaps with counterparties (Morgan Stanley Bank AG and Societe Generale), which introduces counterparty risk. While the exposure is limited to 10% of total fund assets per UCITS guidelines, the presence of these swaps and the associated counterparty risk make the instrument complex under MiFID II rules. The KIID and factsheet also highlight operational and liquidity risks, but the key complexity driver is the swap usage, even though it is not for leverage or synthetic replication.",
    "confidence": 85,
    "risk_level": 3,
    "counterparty_risk": true,
    "securities_lending": true,
    "benchmark_complexity": "low",
    "underlying_assets": "Eurozone government bonds (investment grade, 1-3Y maturity)",
    "additional_notes": "The ETF is UCITS-compliant and physically replicated, which typically suggests non-complex status. However, the use of OTC swaps for purposes other than efficient portfolio management (e.g., securities lending collateral optimization) introduces complexity. The counterparty risk, though limited, is a key factor in the classification. The ETF does not use leverage or inverse strategies, and the underlying assets are straightforward government bonds."
}