{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "synthetic",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of OTC derivatives for index exposure",
            "Currency hedging using forwards",
            "Counterparty Risk"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF, which is presumed non-complex, this presumption is overturned by several factors. The KIID states the fund can use 'OTC derivatives' not just for efficient portfolio management but also 'to generate efficiencies in gaining exposure to the index'. This use of derivatives is integral to the investment strategy, not merely for risk management, and introduces 'counterparty risk', which is explicitly mentioned. This function is akin to using a swap to gain index performance, and under the provided rules, any swap usage mandates a 'complex' classification. Furthermore, this specific share class is currency-hedged using 'currency forwards', another type of derivative. The replication method is not purely physical; the option to use derivatives to replicate the index makes it synthetic or hybrid, which is more opaque and difficult for a retail investor to understand than a simple physical replication ETF. The combination of using OTC derivatives for index exposure and currency forwards for hedging makes the product's structure and risk profile difficult for an average retail investor to understand, thus classifying it as complex under MiFID II."
    }
}