{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Complex Index",
            "Derivative Use for Direct Investment"
        ],
        "classification": "complex",
        "supporting_data": "The UCITS ETF aims to track the NYSE FactSet Global Blockchain Technologies Capped Index. While the primary replication method is physical (holding equity securities), the KIID states that 'The investment manager may use financial derivative instruments (FDIs) (i.e. investments the prices of which are based on one or more underlying assets) to help achieve the Fundu2019s investment objective. FDIs (including FX contracts) may be used for direct investment purposes.' The explicit mention of using FDIs for 'direct investment purposes' suggests a potentially more complex use than solely efficient portfolio management, which is a key differentiator for complexity under MiFID II. Furthermore, the index itself, focusing on blockchain technology companies, is likely to be considered more complex than a standard equity or bond index, potentially requiring a higher level of understanding from retail investors regarding the underlying business models and technological risks. The risk indicator of 'seven' also suggests a higher risk profile, which can be linked to complex underlying assets. While physical replication is generally non-complex, the stated use of derivatives for direct investment, coupled with the complexity of the underlying theme of the index, leads to a classification of complex."
    }
}