{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps",
            "Synthetic Replication"
        ],
        "classification": "complex",
        "supporting_data": "The Xtrackers MSCI Indonesia Swap UCITS ETF uses a synthetic replication method, relying on derivatives (specifically swaps) to track the MSCI Indonesia TRN index.  The KID explicitly states that the fund uses derivatives, and that the fund's returns depend on the performance of these derivatives. This introduces counterparty risk (if a swap counterparty defaults) and collateral risk, making it difficult for retail investors with basic knowledge to fully understand the risks involved.  Even though the ETF is UCITS compliant and does not explicitly use leverage, the central role of derivatives in its investment strategy makes it complex under MiFID II. The ESMA guidelines and the consultation paper strongly suggest that the use of derivatives, especially in a synthetic replication strategy, is a key factor determining complexity.  The lack of direct investment in the underlying assets introduces opacity, increasing the overall complexity of the product."
    }
}