{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "synthetic",
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Swaps",
            "Counterparty Risk",
            "Collateral Risk"
        ],
        "classification": "complex",
        "supporting_data": "The ETF uses an 'Indirect Replication methodology' which involves investing in a 'total return swap (financial derivative instrument)' to gain exposure to the MSCI Emerging Markets Index. MiFID II guidelines and ESMA's interpretations (as seen in CESR/09-295 and ESMA35-36-1640) classify the use of derivatives, particularly swaps, for replicating an index's performance as complex due to inherent risks such as counterparty risk and collateral risk, which are difficult for retail investors to understand. The document explicitly states that 'Derivatives are integral to the Sub-Fund's investment strategies', directly leading to a complex classification. While UCITS ETFs are generally presumed non-complex, the synthetic replication method employing swaps overrides this presumption. The document also mentions 'Emerging Markets risk' and 'Liquidity risk', but these are market risks and do not inherently define structural complexity under MiFID II. However, the core driver for complexity here is the use of synthetic replication via swaps."
    }
}