{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded swaps",
        "Synthetic replication",
        "Counterparty risk",
        "Non-physical replication",
        "Equity basket differing from index"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco MSCI Japan UCITS ETF uses unfunded swap agreements to achieve its investment objective, explicitly stated in the KIID and PRIIPs KID. The Fund does not physically replicate the MSCI Japan Index but holds a basket of equities that differ from the index constituents, swapping the index performance with a counterparty. This synthetic replication introduces counterparty risk, as highlighted in multiple risk disclosures. The Fund is UCITS compliant but relies on derivative instruments (swaps) as an inherent part of its strategy, not merely for risk management. There is no leverage or inverse exposure, and the risk rating is medium (4-6 range depending on document), but the use of unfunded swaps and synthetic replication classifies the ETF as complex under MiFID II. The PRIIPs KID does not carry a specific comprehension warning but emphasizes counterparty risk and the lack of capital protection. The monthly factsheet confirms the synthetic replication method, swap fees, and counterparty risk limitations under UCITS rules. No capital protection or structured features are present, and costs are straightforward with no performance fees. The complexity arises primarily from the synthetic replication via unfunded swaps and the associated counterparty risk, which may reduce transparency and investor understanding compared to physical replication ETFs."
}