{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The Xtrackers FTSE Vietnam Swap UCITS ETF uses derivatives, specifically swaps, as a core element of its investment strategy to replicate the FTSE Vietnam index.  This synthetic replication method introduces counterparty risk (the risk that the swap counterparty defaults) and makes the ETF's structure less transparent than a physically replicated ETF.  While it is a UCITS ETF, meaning it adheres to UCITS regulations, the inherent use of swaps to track the index and the associated counterparty risk automatically classify it as complex under MiFID II, according to both the provided rules and the ESMA guidelines. The regulatory guidance explicitly states that even limited derivative use for EPM can be flagged as complex, especially if it introduces counterparty risk, and in this case, swaps are integral to the strategy.  Even the fact that this is a UCITS compliant fund does not negate the classification of being a 'Complex' asset under MiFID II due to the use of Swap contracts. "
    }
}