{
    "name": "Amundi PEA MSCI USA ESG Selection UCITS ETF - USD",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the presence of a swap agreement for replication purposes triggers complexity under MiFID II. While the ETF does not employ leverage or inverse strategies, the use of unfunded swaps and the associated counterparty risk make it a complex instrument. The risk profile (SRRI 4) and the disclosure of counterparty risk further support this classification.",
    "confidence": 90,
    "counter_argument": "The ETF tracks a straightforward equity index and has a relatively low risk profile (SRRI 4). However, the use of synthetic replication via swaps is a definitive complexity trigger under MiFID II, overriding the simplicity of the underlying asset class.",
    "risk_level": 4,
    "benchmark_complexity": "The underlying MSCI USA ESG Selection P-Series 5% Issuer Capped Index is not inherently complex, but the synthetic replication method introduces additional layers of risk and operational complexity."
}