{
    "fund_name": "AMUNDI MSCI INDIA UCITS ETF - USD",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "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, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the swap structure creates a dependency on the swap counterparty's creditworthiness. While the underlying index (MSCI India) is straightforward, the use of unfunded swaps for replication adds complexity beyond physical replication methods. The risk profile includes significant counterparty risk disclosures, and the fund's performance is directly tied to the swap agreement rather than direct ownership of assets.",
    "confidence": 90,
    "risk_level": 5,
    "counter_argument": "The ETF tracks a well-known equity index and is UCITS-compliant, which might suggest lower complexity. However, the synthetic replication via swaps and explicit derivative usage for core strategy (not just EPM) overrides this, as MiFID II explicitly flags synthetic ETFs with significant derivative exposure as complex due to the additional risks and understanding required.",
    "additional_notes": "The factsheet confirms synthetic replication and swap usage, reinforcing the complexity classification. No leverage or inverse exposure is present, but the swap structure alone is sufficient for a 'complex' designation under MiFID II."
}