{
    "fund_name": "Amundi FTSE 100 UCITS ETF EUR Hedged Acc",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Currency hedging via derivatives",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "confidence": 85,
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract with specific counterparties (Morgan Stanley Bank AG, Societe Generale), which introduces counterparty risk. While the swap is used for hedging currency risk (EUR/GBP), the use of derivatives and the associated risks (counterparty, operational, hedging) make this product complex under MiFID II. The fact sheet confirms the swap usage and counterparty exposure, which are key complexity indicators. The risk profile mentions derivative-related risks explicitly, further supporting the complex classification. The SRRI (risk level) is 3, which is moderate but not the primary factor in this determination. The use of derivatives is not purely for efficient portfolio management but is integral to the fund's strategy, making it complex.",
    "counter_argument": "One could argue that the swap is used for simple currency hedging and the fund tracks a straightforward equity index (FTSE 100), which might suggest non-complexity. However, the explicit counterparty risk and derivative usage override this argument, as MiFID II emphasizes the presence of derivatives and counterparty exposure as complexity triggers.",
    "risk_profile_alignment": "The risk profile (SRRI 3) is moderate, but the derivative-related risks (counterparty, hedging) and the synthetic replication method elevate the complexity beyond the stated risk level."
}