{
    "fund_name": "Amundi STOXX Europe 600 Industrials 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"
    ],
    "classification": "complex",
    "confidence": 90,
    "supporting_data": "The ETF uses synthetic replication via total return swaps, which is a key complexity indicator under MiFID II. While the fund does not employ leverage or inverse strategies, the use of derivatives (specifically swaps) for replication creates counterparty risk and requires understanding of derivative instruments. The KIID explicitly mentions 'financial derivative instruments' and 'counterparty risk' as material risks, which aligns with MiFID II's criteria for complexity. The fact that the fund is UCITS-compliant does not negate the complexity classification, as synthetic replication with swaps is inherently more complex than physical replication. The risk profile (SRRI 3) is moderate, but the derivative-based structure and counterparty exposure are the primary drivers of the 'complex' classification. The PRIIPs KID and factsheet confirm the synthetic replication method and swap usage, reinforcing the complexity determination. The fund's transparency and liquidity do not override the derivative-based replication method's complexity under MiFID II rules."
}