{
    "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 this is a UCITS ETF using physical (optimised) replication, which would typically suggest a non-complex classification, its features lead to a 'complex' determination under MiFID II. The key reasons are its use of Financial Derivative Instruments (FDIs). Firstly, this specific share class is currency-hedged, employing FDIs like FX forward contracts. This hedging mechanism adds a layer of structural complexity and introduces risks, such as imperfect hedging, that are difficult for a typical retail investor to understand. Secondly, the investment policy explicitly states that FDIs 'may be used for direct investment purposes' as part of its optimisation strategy. This goes beyond simple efficient portfolio management (EPM) and makes derivatives integral to how the fund may achieve its objective. The KIID also explicitly identifies 'Counterparty Risk' associated with these derivatives. The combination of currency hedging and the potential for direct investment via derivatives makes the fund's structure and risk profile opaque and not easily understood, thereby overturning the initial UCITS presumption of non-complexity.",
        "final_assessment": "Complex"
    }
}