{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Amundi Euro Stoxx Banks UCITS ETF Acc is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The KIID and factsheet confirm the fund uses physical replication (direct investment in underlying securities) with sampling allowed for optimization. 2. No Leverage or Inverse Exposure: There are no references to leverage, inverse strategies, or amplified returns. 3. Minimal Derivative Usage: While the factsheet mentions counterparty risk from an OTC swap with Morgan Stanley and Societe Generale, this appears to be for securities lending (a common practice in ETFs) rather than core strategy. The swap exposure is capped at 10% of assets, which is typical for UCITS-compliant funds. 4. Underlying Assets: The fund invests in liquid, transparent Eurozone bank equities (top holdings include Santander, Unicredit, BNP Paribas). 5. Risk Profile: The SRRI is 4 (moderate risk), and the fund's risk disclosures are standard for equity ETFs. 6. UCITS Compliance: The fund is fully UCITS-compliant, which inherently limits complexity. The absence of capital protection features, structured products, or contingent bonds further supports the non-complex classification. The factsheet's mention of 'counterparty risk' from swaps is a standard disclosure for UCITS ETFs engaging in securities lending and does not indicate a complex strategy. The swap usage here is for operational efficiency, not as an inherent part of the investment strategy.",
    "confidence": 95
}