{
    "fund_name": "Amundi S&P 500 II UCITS ETF USD Dist",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "inverse": false,
    "derivatives": true,
    "swaps": true,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an OTC swap with Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the S&P 500 is a well-known index, the use of derivatives for replication and the associated counterparty risk make this ETF complex under MiFID II. The KIID explicitly mentions financial derivative instruments and counterparty risk, which are key complexity indicators. The fact that the ETF is UCITS-compliant does not negate the complexity introduced by the synthetic structure. The risk profile, while moderate (SRRI 3), is not the primary determinant of complexity in this case.",
    "confidence": 90
}