{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthethic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps"
        ],
        "classification": "complex",
        "supporting_data": "The ETF is passively managed and aims to track the MSCI Europe Momentum Index using an indirect replication methodology. This methodology involves investing in a total return swap (a financial derivative instrument) to deliver the index's performance. The KIID explicitly states that 'Derivatives are integral to the Sub-Fund's investment strategies.' Under MiFID II rules, the use of derivatives, particularly for index replication through instruments like total return swaps, inherently introduces risks such as counterparty risk and collateral risk, which are not easily understood by retail investors. This integral use of derivatives for replication is a primary driver for classifying the ETF as complex, as it deviates from the baseline presumption of non-complexity for UCITS ETFs. While the underlying index is an equity index, the synthetic replication method makes the ETF complex."
    }
}