{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives",
            "Currency Hedging",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF and is therefore presumed non-complex. However, this presumption is overturned by several factors. The KIID states this specific share class is 'hedged to USD' and that it 'sells currency forwards' to achieve this. The use of derivatives (currency forwards) is therefore integral to the investment objective of this share class and not solely for Efficient Portfolio Management (EPM). This introduces a layer of structural complexity. The KIID also explicitly states the fund 'may use derivatives' to replicate the index where direct investment is not practical, and it acknowledges the 'counterparty risk' associated with OTC derivatives. An average retail investor is unlikely to easily understand the mechanics of currency hedging, the risks of forwards, or the implications of counterparty risk. According to the provided framework (MiFID II Article 25), when derivatives are integral to achieving the investment objective and the structure is difficult for a retail investor to understand, the ETF is classified as complex. The ESMA guidance further clarifies that an instrument's structure determines its complexity, and the use of derivatives to alter cash flows, as is the case with currency hedging, points towards a complex classification."
    }
}