{
    "fund_name": "Amundi Euro Government Inflation-Linked Bond UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Securities Lending",
        "Inflation-Linked Bond Complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses physical replication but engages in securities lending and has counterparty risk exposure through OTC swaps with Morgan Stanley Bank AG and Societe Generale, which introduces complexity. Additionally, the underlying inflation-linked bonds and the potential for tracking error due to sampling replication contribute to the complexity. The presence of derivative instruments and counterparty risk, even if limited, triggers the MiFID II complexity classification.",
    "confidence": 85,
    "risk_level": 4,
    "counter_argument": "The ETF primarily uses physical replication and has a straightforward investment objective of tracking a government inflation-linked bond index. The derivative usage is limited and primarily for efficient portfolio management, which might suggest a non-complex classification. However, the use of OTC swaps and securities lending introduces additional risks that are not easily understood by retail investors, thus overriding the counter-argument.",
    "additional_notes": "The ETF's risk profile is moderate (SRRI 4), but the use of derivatives and counterparty risk exposure, along with the complexity of inflation-linked bonds, justifies the classification as a complex instrument under MiFID II."
}