{
    "fund_name": "Amundi MSCI China ESG Leaders Extra UCITS ETF Acc",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Counterparty risk from OTC swaps",
        "Complex ESG index methodology",
        "China-specific risks"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of OTC swaps with counterparty risk (Morgan Stanley and Societe Generale), which exceeds typical EPM (Efficient Portfolio Management) usage. While the replication method is physical, the fact sheet explicitly mentions counterparty risk from swaps, which is a MiFID II complexity indicator. Additionally, the underlying MSCI China ESG Leaders index has a complex methodology involving ESG scoring and sector exclusions, which may not be easily understood by retail investors. The China-specific risks (e.g., market access, regulatory) further contribute to the complexity. The ETF does not use leverage or inverse strategies, but the combination of swap exposure and index complexity triggers the 'complex' classification.",
    "confidence": 85
}