{
    "name": "Amundi Stoxx Europe Select Dividend 30 - UCITS ETF DIST",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Total Return Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap to track the STOXX Europe Select Dividend 30 Index, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the factsheet confirms the use of a synthetic replication method. While the ETF does not employ leverage or inverse strategies, the reliance on 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,
    "risk_level": 4,
    "counter_argument": "Some may argue that the ETF is non-complex due to its straightforward dividend-focused equity index tracking and UCITS compliance. However, the use of synthetic replication via swaps and the explicit mention of derivatives as integral to the strategy override this argument, as MiFID II explicitly flags synthetic replication and significant derivative usage as complexity indicators.",
    "additional_notes": "The ETF is UCITS-compliant, which typically implies a higher standard of investor protection, but the synthetic replication method and derivative usage still classify it as complex under MiFID II. The absence of leverage or inverse strategies does not negate the complexity introduced by the swap structure."
}