{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthethic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": "Swaps, Counterparty Risk",
        "classification": "complex",
        "supporting_data": "The Xtrackers CSI300 Swap UCITS ETF uses swaps as a core element of its replication strategy.  This synthetic replication method introduces counterparty risk, which is a key factor in determining complexity under MiFID II.  The KID explicitly mentions the use of derivatives and counterparty risk as significant risks,  making it difficult for retail investors with basic knowledge to fully understand.  Even though it's a UCITS ETF, the reliance on swaps to replicate the index, rather than physical replication, outweighs the general UCITS presumption of non-complexity. The complexity of the CSI 300 index itself, with its focus on A-shares and Chinese companies subject to changing tax policies in China, further contributes to the overall complexity of the ETF. The ESMA guidelines clearly state that derivatives, including swaps, generally lead to a complex classification. "
    }
}