{
    "fund_name": "Amundi STOXX Europe 600 Healthcare UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "derivatives": true,
    "swaps": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) to track the STOXX Europe 600 Healthcare Index. This introduces counterparty risk and derivative exposure, which are key indicators of complexity under MiFID II. The KIID explicitly mentions 'financial derivative instruments' and 'counterparty risk,' further supporting the classification. While the ETF does not use leverage or inverse strategies, the use of swaps for replication purposes is sufficient to classify it as complex under MiFID II regulations.",
    "confidence": 90,
    "risk_level": "The risk level is indicated as 4 on the SRRI scale, reflecting moderate risk, but the complexity arises from the synthetic replication method rather than the risk level itself.",
    "counter_argument": "Some might argue that the ETF is UCITS-compliant and has a straightforward objective of tracking a well-known index, which could suggest it is non-complex. However, the use of synthetic replication via swaps overrides this argument, as MiFID II explicitly considers such structures complex due to the additional risks and understanding required by investors.",
    "additional_notes": "The factsheet confirms the synthetic replication method and the use of swaps, reinforcing the complexity classification. The presence of counterparty risk and derivative instruments in the KIID further supports this determination."
}