{
    "name": "Amundi MSCI Japan UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Counterparty Risk from Swaps",
        "Derivative Usage for Optimization"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but acknowledges the use of financial derivative instruments for optimization, including OTC swaps with counterparties like Morgan Stanley and Societe Generale. While the replication method is physical, the presence of swaps and derivatives introduces counterparty risk and potential complexity. The KIID explicitly mentions risks associated with financial derivative instruments, including leverage risk and high volatility risk. The factsheet further confirms the use of an OTC swap, which, despite being within UCITS guidelines (limited to 10% exposure), adds a layer of complexity due to counterparty risk and potential valuation challenges. The ETF's risk profile (SRRI 4) and the disclosure of derivative-related risks support the classification as complex under MiFID II, as these factors may not be easily understood by retail investors.",
    "confidence": 85,
    "counter_argument": "The ETF is physically replicated and UCITS-compliant, which typically suggests non-complex classification. The derivative usage is limited and primarily for optimization, not leverage or inverse strategies. However, the explicit mention of OTC swaps and counterparty risks, along with derivative-related risks in the KIID, tilts the classification toward complex due to the additional risks and potential lack of transparency for retail investors.",
    "risk_level": 4
}