{
    "fund_name": "Amundi Nasdaq-100 II UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex index tracking"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) to track the NASDAQ-100 Notional Net Total Return Index. This introduces counterparty risk (Morgan Stanley Bank AG, Societe Generale) and derivative-related risks. While the index itself is not inherently complex, the use of synthetic replication with swap agreements triggers MiFID II complexity classification. The fact sheet confirms the swap usage and counterparty risk, which are key complexity indicators. The ETF does not use leverage or inverse strategies, but the synthetic structure and derivative exposure make it complex under MiFID II rules.",
    "confidence": 90,
    "counter_argument": "One could argue that since the ETF tracks a straightforward equity index and doesn't use leverage or inverse strategies, it should be non-complex. However, MiFID II explicitly considers synthetic replication with swap agreements as a complexity factor, regardless of the underlying index's complexity. The presence of counterparty risk from the swap structure overrides this argument.",
    "risk_level": "Medium (SRRI 5 out of 7)",
    "additional_notes": "The ETF is UCITS compliant and tracks a major equity index, but the synthetic replication method with swap agreements makes it complex under MiFID II. The counterparty risk and derivative exposure are the primary drivers of this classification."
}