{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for currency hedging",
            "Use of derivatives for direct investment purposes",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF using physical (optimized) replication, which would typically support a non-complex classification, its features lead to a 'complex' determination. The primary driver is the use of Financial Derivative Instruments (FDIs). The KIID states FDIs, including FX forward contracts, will be used for two main reasons: 1) as a structural component for the GBP Hedged share class, and 2) for 'direct investment purposes'. The currency hedging is integral to this share class's investment objective and introduces risks and mechanics, such as imperfect hedging and counterparty risk, which are difficult for an average retail investor to understand. The KIID explicitly lists 'Counterparty Risk' as a key risk not captured by the standard risk indicator, stating that the insolvency of a counterparty to derivatives may expose the fund to financial loss. This goes beyond simple market risk. According to the MiFID II framework, when derivatives are integral to the investment objective and introduce risks that are hard for retail investors to grasp, the instrument is deemed complex. This structural complexity overturns the initial presumption of non-complexity for a UCITS ETF.",
        "final_assessment": "Complex"
    }
}