{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Potential for swap usage for currency hedging (even if for EPM), triggering complexity as per explicit instruction.",
            "Derivatives introduce counterparty risk, which can be difficult for retail investors to understand."
        ],
        "classification": "complex",
        "supporting_data": "The fund is a UCITS ETF, which initially benefits from a presumption of non-complexity. Its investment policy indicates it invests primarily in equity securities, suggesting a physical replication method. The fund is actively managed and aims to outperform a transparent index (MSCI Emerging Markets). It may use derivatives for efficient portfolio management (EPM) and currency hedging purposes. While the provided MiFID II rules generally classify EPM derivative use as non-complex if limited and with minimal impact on risk-return, a strict overriding instruction mandates that if 'any Swap usage is identified', the classification must be 'complex'. Currency hedging frequently involves the use of currency swaps or forwards (which are a type of derivative), thus, the potential for 'swap usage' for currency hedging purposes is identified. This factor, despite the fund's otherwise straightforward investment approach and underlying asset class, leads to a complex classification based on the specific instruction provided. The high risk rating (6/7) is attributed to market volatility inherent in emerging markets, not structural complexity, and the underlying index is transparent. However, the presence of derivatives for hedging purposes, and the potential for these to include swaps, is the decisive factor."
    }
}