{
    "complex": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "OTC Swap with counterparty risk",
        "Physical replication with potential swap usage for hedging"
    ],
    "classification": "non-complex",
    "supporting_data": "The Amundi MSCI Japan UCITS ETF Acc is classified as non-complex under MiFID II. While it uses physical replication as its primary method, the fact sheet mentions the use of an OTC swap with counterparties (Morgan Stanley and Societe Generale) for hedging purposes. However, this swap usage is within UCITS guidelines (counterparty exposure =10% of assets) and appears to be for efficient portfolio management rather than a core strategy. The fund tracks a straightforward equity index (MSCI Japan Net Total Return) with no leverage, inverse exposure, or complex structured features. The risk profile (SRRI 3) aligns with typical equity ETFs, and the documentation emphasizes transparency (daily NAV, published holdings). The only potential complexity factor is the counterparty risk from swaps, but this is mitigated by UCITS limits and the fund's overall simplicity. The absence of leverage, inverse strategies, or capital protection mechanisms further supports the non-complex classification.",
    "confidence": 90
}