{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Indirect Replication"
    ],
    "classification": "complex",
    "supporting_data": "The AMUNDI NASDAQ-100 UCITS ETF uses synthetic replication via a total return swap, which is a financial derivative instrument. This introduces counterparty risk and reliance on the swap provider's performance. The KIID explicitly states that derivatives are integral to the investment strategy, not merely for efficient portfolio management. The presence of significant counterparty risk and the synthetic replication method are key indicators of complexity under MiFID II. Additionally, the fund's risk profile includes liquidity risk and operational risk, which are more pronounced in synthetic ETFs. The factsheet confirms the synthetic replication type and the use of swaps, reinforcing the complexity classification.",
    "confidence": 90,
    "counter_argument": "Some might argue that the fund is UCITS-compliant and tracks a well-known index, suggesting it could be non-complex. However, the use of synthetic replication and the explicit mention of derivatives as integral to the strategy override this argument, as MiFID II explicitly flags synthetic replication and significant derivative usage as complexity indicators.",
    "risk_level": 5
}