{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives for direct investment",
            "Holds complex bonds (emerging market, sub-investment grade, defaulted)",
            "Counterparty and liquidity risks"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF employing an optimised physical replication method, which are factors that typically support a non-complex classification, several features lead to a 'complex' determination under MiFID II.The most critical factor is the fund's policy on derivatives. The KIID states that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes'. This goes beyond simple Efficient Portfolio Management (EPM) for hedging or cost reduction. Using derivatives for direct investment makes them integral to the investment strategy and introduces risks, such as counterparty risk (explicitly mentioned in the KIID), that are difficult for an average retail investor to understand.Furthermore, the underlying index, the J.P. Morgan EMBI Global Core Index, consists of assets that are themselves complex. It includes bonds from emerging markets which carry higher political and liquidity risks. Crucially, the index is not limited to high-quality debt; it includes 'subinvestment grade securities' and 'securities in default'. Assessing the risks associated with defaulted and high-yield emerging market debt requires a sophisticated level of financial knowledge, making the ETF's risk profile opaque to a typical retail investor.While securities lending is present, the primary drivers for the complex classification are the use of derivatives for investment purposes and the inherently complex nature of the underlying bond portfolio. These elements combined overturn the initial non-complex presumption for a UCITS product."
    }
}