{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swap",
        "Counterparty risk exposure",
        "Use of derivatives as inherent part of strategy"
    ],
    "classification": "complex",
    "supporting_data": "The UBS MSCI AC Asia ex Japan SF UCITS ETF uses synthetic replication through a fully funded total return swap with UBS AG as counterparty, as explicitly stated in the KIID and confirmed by the factsheet. The Fund invests in financial derivative instruments (FDIs) with UBS AG, swapping the performance of the MSCI AC Asia ex Japan Net Total Return Index against the performance of a basket of securities held by the Fund. This swap structure means the Fund's performance depends on the counterparty's ability to meet its obligations, introducing significant counterparty risk. The Fund does not use physical replication or direct purchase of underlying securities as the main strategy. There is no leverage or inverse exposure mentioned. The risk profile in the KIID rates the Fund at 6 out of 7, indicating a high risk level, partly driven by counterparty risk and market volatility. The PRIIPs KID rates the risk lower at 4 out of 7 but confirms the use of swaps and counterparty risk. Costs are straightforward with no performance fees, but swap-related costs are embedded. The Fund is UCITS compliant. The synthetic replication and swap usage are inherent to the Fund's strategy, not merely for risk management, which under MiFID II rules classifies the ETF as complex. There are no capital protection or structured product features. The underlying index is broad and liquid, but the synthetic structure and counterparty exposure increase complexity. No leverage or inverse features are present. Therefore, despite a relatively transparent index and no leverage, the synthetic swap structure and counterparty risk drive the classification as complex under MiFID II."
}