{
    "type": "ETF",
    "ucits": true,
    "fund_name": "UBS (Lux) Fund Solutions - MSCI Japan UCITS ETF, class (JPY) A-dis",
    "investment_objective": "Passive replication of MSCI Japan Index (Net Return) via direct investments in substantially all component securities and/or derivatives to gain exposure or efficiencies",
    "primary_asset_class": "Equity",
    "geographic_focus": "Japan",
    "replication_method": "physical",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": "Use of OTC derivatives (swaps) for replication efficiency and counterparty risk",
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication (full replication) investing directly in Japanese equities of the MSCI Japan Index. However, the KIID and PRIIPs KID explicitly state that derivatives, including OTC swaps, may be used where direct replication is not possible or to generate efficiencies. The use of OTC derivatives introduces counterparty risk, mitigated by collateral policies. The fund is UCITS compliant and does not employ leverage or inverse strategies. The risk profile in the KIID is high (category 6) due to equity market volatility, but the PRIIPs KID shows a medium risk (category 4) reflecting a more conservative risk assessment. The monthly factsheet confirms physical replication as the primary method but acknowledges swap usage for efficiency. No leverage or capital protection features are present. Costs are straightforward with a low TER and no performance fees. The PRIIPs KID includes a comprehension warning stating the product is 'not simple and may be difficult to understand,' which aligns with MiFID II complexity considerations. Although derivatives are used for replication efficiency rather than active risk management, the presence of OTC swaps and counterparty risk exposure mandates classification as complex under MiFID II. There is no leverage or structured product exposure, but the swap usage and counterparty risk are sufficient complexity drivers.",
    "risk_level_assessment": "The fund's stated risk profile is medium to high due to equity market volatility. The complexity classification is driven not by leverage or structured features but by the use of OTC derivatives (swaps) and associated counterparty risk, which may reduce retail investors' ability to fully understand the product's risk profile."
}