{
    "fund_name": "Amundi FTSE 100 UCITS ETF Dist",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure from swap agreements",
        "Potential complexity in understanding swap mechanics"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract with counterparties like Morgan Stanley and Societe Generale. While the swap usage is within UCITS limits (=10% exposure to any single counterparty), the reliance on derivatives and counterparty risk introduces complexity. The FTSE 100 index itself is relatively straightforward, but the synthetic structure and counterparty exposure make this ETF complex under MiFID II. The fact sheet confirms the use of swaps for replication, and the KIID highlights counterparty risk as a material risk factor. The ETF does not use leverage or inverse strategies, but the synthetic nature and derivative exposure are sufficient to classify it as complex.",
    "confidence": 85
}