{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for direct investment",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF that uses physical replication to track its index, which are factors that typically support a 'non-complex' classification. However, the Key Investor Information Document (KIID) explicitly states that the fund may use Financial Derivative Instruments (FDIs) for 'direct investment purposes'. This phrasing goes beyond simple Efficient Portfolio Management (EPM), such as hedging or managing cash flows. The use of derivatives for direct investment introduces a layer of structural complexity and specific risks, such as the 'Counterparty Risk' that is highlighted in the KIID as a risk not fully captured by the standard risk indicator. According to MiFID II guidelines, a product is considered complex if its structure or risks are difficult for a retail investor with basic knowledge to understand. The potential use of derivatives and the associated counterparty risk meet this criterion, thereby overriding the presumption of non-complexity for a UCITS ETF. The asset is therefore classified as 'complex'."
    }
}