{
    "name": "AMUNDI MSCI EUROPE MOMENTUM FACTOR UCITS ETF - EUR",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap to track the MSCI Europe Momentum Index, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the fact sheet confirms the replication type as synthetic. While the ETF does not employ leverage or inverse strategies, the use of swaps and the associated counterparty risk make it complex under MiFID II rules. The risk profile includes significant counterparty risk disclosures, and the synthetic structure requires understanding of swap mechanics, which may not be straightforward for retail investors.",
    "confidence": 90,
    "risk_level": 4,
    "counter_argument": "Some might argue that the ETF is non-complex because it does not use leverage or inverse strategies and tracks a straightforward equity index. However, the synthetic replication method and the explicit reliance on derivatives for performance tracking override this argument, as MiFID II considers synthetic ETFs inherently more complex due to counterparty risk and the need for investors to understand the swap structure.",
    "additional_notes": "The ETF is UCITS-compliant, which imposes certain investor protection standards, but this does not negate the complexity introduced by synthetic replication. The fact sheet and KIID both highlight the use of swaps and counterparty risk, reinforcing the classification as complex."
}