{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for EPM introducing counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF that uses physical replication to track the FTSE Brazil 30/18 Capped Index, which are strong indicators of a non-complex product. However, the Key Investor Information document explicitly states that 'The Fund may use derivatives for efficient portfolio management purposes only.' Crucially, it also lists 'Counterparty risk' as a material risk, defining it as 'the risk of failure of financial institutions or agents (when serving as a counterparty to financial contracts) to perform their obligations.'Under MiFID II, the need for a retail investor to understand counterparty risk, which is a structural risk rather than a market risk, introduces a layer of complexity. As per the provided assessment rules, an ETF is complex if its risks are 'difficult for retail investors to understand,' and counterparty risk falls into this category. The ESMA Supervisory Briefing (ESMA35-36-1640) also reinforces that firms must carefully assess instruments that embed a derivative or 'incorporate a structure which makes it difficult for the client to understand the risk involved.' While the derivatives are used for EPM and not for the core strategy, their presence introduces a risk that is not straightforward, thereby overturning the initial presumption of non-complexity for a UCITS vehicle.",
        "final_assessment": "Complex"
    }
}