{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for investment purposes",
            "Potential for losses greater than amount invested",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF using physical (sampling) replication, which initially presumes a non-complex classification. However, this presumption is overturned by several factors outlined in the Key Investor Information Document (KIID). The KIID states the Sub-Fund may use derivatives not only for 'efficient portfolio management purposes' but also 'for investment purposes in order to seek to increase return'. This use for return enhancement goes beyond the limited scope allowed for non-complex products. The KIID further highlights 'Derivatives risk', explicitly warning that 'Certain derivatives may result in losses greater than the amount originally invested,' which is a key indicator of a complex structure that is difficult for a retail investor to understand. The document also lists 'Counterparty risk' as a material risk. The combination of using derivatives for investment purposes (not just EPM), the potential for leveraged losses, and the introduction of counterparty risk makes the ETF structurally complex under MiFID II rules."
    }
}