{
    "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 Dist 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 a 'financial derivative instrument' (FDI) and references counterparty risk associated with swap agreements. The factsheet further confirms the use of an OTC swap with counterparties like Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the ETF does not use leverage or inverse strategies, the reliance on swaps and the associated counterparty risk, as well as the synthetic replication method, are key factors that classify this ETF as complex under MiFID II. The risk profile also highlights the risks of financial derivative instruments, including leverage risk, high volatility, and liquidity risk.",
    "confidence": 90,
    "counter_argument": "Some might argue that the ETF is non-complex because it is UCITS-compliant and tracks a well-known index (FTSE 100) with a straightforward objective. However, the use of synthetic replication and the explicit mention of derivative instruments and counterparty risk override this argument, as these elements introduce complexity that may not be easily understood by retail investors.",
    "risk_level": "The risk level is indicated as moderate (SRRI 4), but the presence of derivative instruments and counterparty risk elevates the complexity classification under MiFID II."
}