{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Total Return Swaps",
            "Counterparty Risk",
            "Collateral Risk"
        ],
        "classification": "complex",
        "supporting_data": "The Sub-Fund employs an indirect replication methodology using a total return swap (financial derivative instrument) to gain exposure to the MSCI Emerging Markets Latam Index. This use of derivatives, specifically swaps, to replicate index performance is a key indicator of complexity. MiFID II guidance, including ESMA's, generally classifies instruments integral to their investment strategy and relying on derivatives as complex due to the associated risks (counterparty risk, collateral risk) which are not easily understood by retail investors. The document explicitly states 'Derivatives are integral to the Sub-Fund's investment strategies.' This directly triggers a complex classification according to the rules. While UCITS are generally presumed non-complex, the explicit and integral use of swaps to achieve the investment objective overrides this presumption."
    }
}