{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Complex underlying index",
            "Counterparty and credit risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, which is presumptively non-complex, its classification is 'complex' due to several overriding factors. The Key Investor Information document explicitly states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes'. This goes beyond simple Efficient Portfolio Management (EPM) and means derivatives are integral to the investment strategy, introducing counterparty risk that is difficult for a typical retail investor to understand. Furthermore, the ETF tracks a complex index, the J.P. Morgan GBI-EM Global Diversified, which consists of local currency emerging market government bonds. The KIID notes these may have 'a relatively low credit rating or which are unrated,' and the index has 'no minimum credit rating requirement.' This exposes the investor to significant and hard-to-understand risks, including heightened credit risk, liquidity risk, and political risk, in addition to the counterparty risk from derivatives. The combination of using derivatives for investment and the inherent complexity and risk profile of the underlying assets makes the ETF difficult for a retail investor with basic knowledge to comprehend, thus warranting a 'complex' classification under MiFID II.",
        "final_assessment": "Complex"
    }
}