{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Financial Derivative Instruments"
    ],
    "classification": "complex",
    "supporting_data": "The Amundi MSCI China UCITS ETF Acc uses synthetic replication via an over-the-counter swap contract (financial derivative instrument) to track the MSCI China Net Total Return USD Index. The KIID explicitly mentions the use of financial derivative instruments (FDIs) and highlights counterparty risk associated with swap agreements. The fund's risk profile includes specific warnings about the risks of financial derivative instruments, including leverage risk, high volatility risk, and liquidity risk. The presence of swap agreements and the associated counterparty risk, along with the use of derivatives for replication, are key indicators of complexity under MiFID II. Additionally, the fund's risk level is rated at 5 out of 7, indicating a higher risk profile, which often correlates with complexity.",
    "confidence": 90,
    "counter_argument": "While the fund is UCITS compliant and aims to track a well-known index, the use of synthetic replication via swaps introduces complexity that may not be easily understood by retail investors. The counterparty risk and the potential for significant tracking error due to the derivative instruments further support the classification as complex. Even though the fund does not use leverage or inverse strategies, the synthetic replication method and the associated risks are sufficient to classify it as complex under MiFID II.",
    "risk_level": 5
}