{
    "fund_name": "AMUNDI S&P 500 BUYBACK UCITS ETF - USD",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using total return swaps",
        "Counterparty risk exposure from swap agreements",
        "Indirect replication methodology"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps to achieve exposure to the S&P 500 Buyback Index, which introduces counterparty risk and derivative exposure. While the fund itself is not leveraged or inverse, the use of swaps for replication and the indirect exposure to the index through derivatives are key factors that trigger the 'complex' classification under MiFID II. The KIID explicitly mentions that derivatives are integral to the investment strategy, and the fact sheet confirms the synthetic replication method. The risk profile includes counterparty risk warnings, which further supports the complex classification. The fund is UCITS-compliant, but the synthetic structure and derivative usage still meet the criteria for complexity under MiFID II.",
    "confidence": 90
}