{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Currency hedging using derivatives",
            "OTC derivatives",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "Although the asset is a UCITS ETF which is presumed non-complex and uses physical replication for its core index tracking, it is classified as complex due to the currency hedging strategy applied to this specific share class. The KIID states that the fund 'sells currency forwards at the one-month forward rate' to hedge currency risk. This use of derivatives (currency forwards) is integral to the investment objective of the hedged share class, not merely for efficient portfolio management. The document explicitly mentions that 'The use of OTC derivatives further engenders counterparty risk'. The introduction of a derivative-based hedging strategy and the associated counterparty risk makes the product's structure and risk-return profile difficult for an average retail investor to understand, thus overriding the UCITS presumption of non-complexity. According to MiFID II rules, if derivatives are integral to achieving the investment objective and introduce risks like counterparty risk, the instrument is considered complex. The ESMA guidance also suggests that structures making it difficult for a client to understand the risk, such as those involving derivatives, lead to a complex classification."
    }
}