{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "complex": false,
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "complex_factors": [
            "Synthetic replication using swaps",
            "Counterparty risk",
            "Collateral risk"
        ],
        "supporting_data": "The ETF uses indirect replication via an over-the-counter swap contract, which is a financial derivative instrument. This synthetic replication method is a primary driver for classifying it as complex under MiFID II rules, as it introduces counterparty risk and collateral risk that are not easily understood by retail investors. While the ETF tracks a standard index (MSCI Pacific Ex Japan Net Total Return), the reliance on derivatives for replication is key. The KID explicitly mentions 'Risk of Financial derivative Instruments' and notes that these can induce risks such as leverage risk, high volatility risk, valuation risk, or liquidity risk. The explanation also details 'Counterparty risk' as a distinct risk. According to MiFID II and CESR guidelines, the use of derivatives for replication, especially swaps, inherently makes an instrument complex due to the opacity and associated risks for retail investors.",
        "classification": "complex"
    }
}