{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication",
        "Swap counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The UBS MSCI ACWI SF UCITS ETF uses synthetic replication via a fully funded total return swap with UBS AG, London Branch as the counterparty. The fund does not invest directly in all underlying securities but swaps the index performance with UBS, receiving collateral in the form of G10 government bonds, supranational bonds, and cash. The KIID and PRIIPs KID explicitly mention the use of financial derivative instruments (FDIs) and swap agreements as the core mechanism to achieve the investment objective. There is significant counterparty risk associated with UBS as the swap counterparty, which is highlighted as a material risk factor. The fund is UCITS compliant but the synthetic replication and swap usage inherently introduce complexity under MiFID II. There is no leverage or inverse exposure, and derivatives are used as an inherent part of the strategy rather than for risk management only, so derivatives are marked true. The risk profile is medium to high (category 5 in KIID, 4 in PRIIPs KID), reflecting the counterparty and market risks. Costs are straightforward with a TER of 0.21% and no performance fees. The fund tracks a broad, well-diversified equity index (MSCI ACWI) with no complex underlying assets like contingent bonds or structured products. However, the synthetic replication and swap counterparty exposure are sufficient to classify this ETF as complex under MiFID II rules."
}