{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of Financial Derivative Instruments (FDIs) for direct investment purposes to gain exposure to certain securities.",
            "Explicit mention of Counterparty Risk arising from derivatives and other instruments, which introduces risks difficult for retail investors to understand."
        ],
        "classification": "complex",
        "supporting_data": "The iShares Core MSCI EM IMI UCITS ETF is indeed a UCITS-compliant Exchange Traded Fund, which typically benefits from a presumption of non-complexity. Its primary replication method is physical, involving direct holding of the underlying equity securities, which also generally supports a non-complex classification. However, the Key Investor Information Document (KID) explicitly states that 'Financial Derivative Instruments (FDIs) may be used for direct investment purposes. In order to gain exposure to certain securities in emerging markets that make up the Index'. This goes beyond mere efficient portfolio management (EPM), indicating that derivatives are an integral part of achieving the fund's investment objective by gaining direct exposure, rather than solely for risk management or cost reduction. Furthermore, the KID's risk profile section specifically highlights 'Counterparty Risk: The insolvency of any institutions providing services such as safekeeping of assets or acting as counterparty to derivatives or other instruments, may expose the Share Class to financial loss.' According to the MiFID II rules provided, if derivatives are integral to achieving the investment objective and introduce risks like counterparty risk that are difficult for retail investors to understand, the ETF is classified as complex. Even if swaps are not explicitly named as the type of FDI, the general use of FDIs for 'direct investment purposes' and the explicit mention of associated counterparty risk are sufficient to overturn the UCITS presumption of non-complexity under the provided MiFID II framework, leading to a complex classification. The fund does not indicate significant leverage or an inverse strategy."
    }
}