{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI AC Asia ex Japan ESG Swap UCITS ETF",
    "investment_objective": "To reflect the performance of the MSCI AC Asia ex Japan Low Carbon SRI Selection Capped Index, which tracks large and mid-cap companies from developed and emerging Asian markets (excluding Japan) with high ESG performance and low carbon exposure.",
    "primary_asset_class": "Equity",
    "geographic_focus": "Asia ex Japan (developed and emerging markets)",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreements",
        "Counterparty risk exposure",
        "Use of derivatives inherent to strategy",
        "Emerging markets exposure",
        "Complex ESG and carbon screening index"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through swap agreements with one or more counterparties to achieve its investment objective, as explicitly stated in both the KIID and PRIIPs KID. The fund does not invest directly in the underlying securities but enters into financial contracts (derivatives) to obtain the return on the index. The replication method is described as 'Indirect Replication (Swap)' in the factsheet. There is explicit mention of counterparty risk, including the risk of counterparty insolvency leading to potential losses. The fund is UCITS compliant but uses derivatives not just for risk management but as an inherent part of the strategy, which mandates classification as complex under MiFID II. There is no leverage or inverse exposure. The underlying index is complex, involving ESG and low carbon criteria with caps on constituent weights, adding to complexity. The risk profile is medium (4 out of 7), which aligns with the presence of derivative and counterparty risks but no leverage. Costs include ongoing charges around 0.65% with no performance fees, and no leverage-related costs. The PRIIPs KID does not carry a specific comprehension warning but highlights derivative and counterparty risks. Overall, the synthetic swap-based replication and counterparty exposure are the primary drivers of complexity classification despite the fund\u2019s medium risk rating and lack of leverage.",
    "risk_level": 4
}