{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Pakistan Swap UCITS ETF",
    "investment_objective": "To reflect the performance of the MSCI Pakistan Investable Market Total Return Net index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Pakistan",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via swap agreements",
        "Counterparty risk exposure",
        "Emerging and frontier market exposure",
        "Derivative usage inherent to strategy"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication by entering into swap agreements with counterparties to gain exposure to the MSCI Pakistan Investable Market Total Return Net index rather than physically holding the underlying securities. The KIID explicitly states the fund does not invest directly in the index components and that returns depend on derivatives used. The fund carries counterparty risk from swap counterparties, which is highlighted as a significant risk. The risk profile is high (category 6 in KIID, 5 in PRIIPs KID), reflecting volatility and derivative-related risks. The fund invests in an emerging and frontier market (Pakistan), which adds complexity due to political, liquidity, and regulatory risks. There is no leverage or inverse exposure, but the use of swaps and derivatives as a core part of the investment strategy, combined with counterparty risk and emerging market exposure, drives the classification as complex under MiFID II. The PRIIPs KID confirms the fund is a UCITS ETF with synthetic replication and derivative use inherent to the strategy, with no capital protection or leverage. Costs include ongoing charges of 0.85% p.a. and derivative-related costs are embedded in replication costs. No performance fees or leverage are present. The factsheet confirms indirect replication via swaps and highlights counterparty risk and emerging market risks. No mention of capital protection or structured features is found. Overall, the synthetic swap-based replication and counterparty risk are the main complexity drivers, despite the fund's straightforward index-tracking objective and lack of leverage.",
    "risk_level_assessment": "The fund's risk profile is high (category 6 in KIID, 5 in PRIIPs KID), consistent with the volatility of emerging market equities and the inherent risks of synthetic replication via swaps. This aligns with the complexity classification, as the derivative and counterparty risks increase the difficulty for retail investors to fully understand the product's risk-return profile."
}