{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Emerging Markets Swap UCITS ETF",
    "investment_objective": "To reflect the performance of the MSCI Total Return Net Emerging Markets Index",
    "primary_asset_class": "Equity",
    "geographic_focus": "Global Emerging Markets",
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via total return swaps",
        "Counterparty risk exposure",
        "Use of derivatives for index exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication through total return swaps to achieve its investment objective, as explicitly stated in both the KIID and PRIIPs KID documents. The fund does not invest directly in the underlying securities but enters into financial contracts (derivatives) with swap counterparties to obtain index returns. The KIID highlights counterparty risk and derivative risk as significant risks. The fund is UCITS compliant but the use of unfunded swap agreements and derivative instruments for replication classifies it as complex under MiFID II. There is no leverage or inverse exposure, and the risk rating is moderate (4/7 in PRIIPs KID), but the synthetic structure and counterparty exposure drive the complexity classification. The factsheet confirms indirect replication via swaps and no leverage. No capital protection or structured features are present. Costs are straightforward with no performance fees, but swap-related costs are implied. The complexity arises mainly from the synthetic replication method and associated counterparty and derivative risks, which may not be easily understood by retail investors, fulfilling MiFID II complexity criteria."
}