{
    "name": "AMUNDI S&P 500 BUYBACK UCITS ETF - EUR",
    "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 factsheet 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 (SRRI 4) and the presence of liquidity and operational risks further support this classification.",
    "confidence": 90,
    "counter_argument": "The ETF tracks a straightforward equity index (S&P 500 Buyback) and does not use leverage or inverse strategies. The tracking error is minimal, and the underlying assets are liquid equities. However, the use of synthetic replication via swaps overrides these factors, as MiFID II explicitly flags synthetic ETFs as complex due to counterparty risk and derivative exposure.",
    "risk_level": 4
}