{
    "fund_name": "Amundi Euro Government Bond 15+Y 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, Societe Generale",
        "Securities Lending Programme",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex under MiFID II due to the use of OTC swaps with counterparties (Morgan Stanley Bank AG, Societe Generale) and a securities lending programme, which introduces counterparty risk. While the primary replication method is physical, the presence of these derivative-related activities and counterparty exposure makes the fund complex. The fact that the exposure to the counterparty cannot exceed 10% of the total fund assets is noted, but the existence of such arrangements is sufficient to trigger the complex classification under MiFID II. The fund does not use leverage or inverse strategies, and the underlying assets (long-duration Eurozone government bonds) are relatively straightforward. However, the derivative usage for risk management and the associated counterparty risk are the primary factors driving the complex classification.",
    "confidence": 85
}