{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Derivative Instruments"
    ],
    "classification": "complex",
    "supporting_data": "The Amundi FTSE 100 UCITS ETF Acc uses synthetic replication via an over-the-counter swap contract (financial derivative instrument) to achieve its investment objective. The KIID explicitly mentions the use of 'financial derivative instruments' and highlights counterparty risk associated with swap agreements. The factsheet confirms the synthetic replication method and identifies specific counterparties (Morgan Stanley Bank AG, Societe Generale). While the ETF does not employ leverage or inverse strategies, the use of swaps for replication introduces complexity through counterparty exposure and derivative-related risks. The risk profile includes warnings about financial derivative instruments inducing various risks, and the SRRI risk level is moderate but accompanied by detailed derivative risk disclosures.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and tracks a straightforward equity index (FTSE 100), which might suggest simplicity. However, the synthetic replication via swaps and explicit counterparty risk exposure override this argument, as MiFID II explicitly flags derivative-based replication as a complexity indicator.",
    "risk_level": "The SRRI risk level is moderate (4 out of 7), but the derivative and counterparty risks elevate the complexity classification under MiFID II."
}