{
    "fund_name": "Amundi Euro Government Bond 5-7Y UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "OTC Swap with Morgan Stanley Bank AG and Societe Generale",
        "Securities Lending Programme",
        "Potential counterparty risk from swap agreements"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of OTC swaps with Morgan Stanley Bank AG and Societe Generale, which introduces counterparty risk. While the ETF uses physical replication as its primary method, the presence of swaps and securities lending programmes adds complexity. The fact that the ETF is UCITS-compliant and tracks a relatively straightforward government bond index mitigates some of the complexity, but the derivative usage and counterparty risk are significant enough to warrant a 'complex' classification under MiFID II. The fact that the swap exposure is limited to 10% of total assets and the ETF is physically replicated helps, but the presence of derivatives beyond efficient portfolio management triggers the complexity classification.",
    "confidence": 85
}