{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Non-Deliverable Forwards",
            "Derivative use for investment objective",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The Fund is a UCITS ETF, which are generally presumed non-complex. However, this presumption is overturned due to the explicit mention and potential use of financial derivative instruments (FDIs) for purposes beyond efficient portfolio management (EPM). The Key Investor Information Document (KID) states that the Fund 'may also (or alternatively) invest in financial derivative instruments (FDIs) which relate to the Index or constituents of the Index'. This phrasing, particularly 'or alternatively', indicates that derivatives, including 'swaps (including equity swaps and swaps on the Index)' and 'non-deliverable forwards (NDFs)', can be an inherent element of the investment strategy to gain index exposure, rather than solely for risk management. According to the MiFID II complexity assessment rules provided, 'If any element of ... any Swap usage is identified then the 'classification' must be 'complex''. The use of swaps and NDFs introduces complex risks such as counterparty risk and collateral management, which are typically difficult for retail investors with basic knowledge to understand. While the Fund 'normally' uses physical replication, the alternative use of these complex derivatives for index exposure overrides the non-complex presumption. The high-risk rating (6/7) reflects market volatility but does not, on its own, determine structural complexity; however, it aligns with the overall complex nature stemming from derivative usage."
    }
}