{
    "fund_name": "Amundi BEL 20 UCITS ETF Dist",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "OTC Swap with counterparty",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses an OTC swap with Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the ETF is physically replicated, the presence of swaps (even for efficient portfolio management) and counterparty risk exposure triggers the MiFID II complexity classification. The fact that the swap exposure is capped at 10% of total assets does not negate the complexity determination under MiFID II rules. The KIID and factsheet confirm the use of derivatives (swaps) and counterparty risk, which are key complexity indicators. The ETF's risk profile is otherwise straightforward (equity exposure to Belgian stocks), but the derivative usage and counterparty risk make it complex under MiFID II.",
    "confidence": 90
}