{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Swaps for index replication",
            "Counterparty risk",
            "Synthetic replication"
        ],
        "classification": "complex",
        "supporting_data": "The ESG Value Europe UCITS ETF is a UCITS compliant fund, which typically presumes non-complexity. However, the Key Investor Information Document (KID) explicitly states that the sub-fund seeks to replicate the index performance 'by investing in a substitute basket, composed of, inter alia, shares of companies, debt securities or cash (synthetic replication)'. It further clarifies that 'When investing in a basket of securities called substitute basket the performance is swapped with the performance of the index, generating counterparty risk.' This directly triggers the 'Complex' classification under the provided MiFID II rules, which state that an ETF is complex 'if derivatives are integral to achieving its investment objective, such as using swaps... to replicate the index's performance.' The presence of swaps introduces risks like counterparty risk, which are identified as difficult for retail investors to understand. While the underlying index is transparent, the synthetic replication method fundamentally introduces structural complexity that overrides the initial UCITS presumption of non-complexity, aligning with the MiFID II framework's nuances regarding derivative use and ease of understanding for retail investors, as well as the specific instruction that 'If any element of... any Swap usage is identified then the 'classification' must be 'complex'."
    }
}