{
    "type": "ETC",
    "ucits": false,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Complex Underlying Index",
        "Counterparty Risk",
        "Termination Risk"
    ],
    "classification": "complex",
    "supporting_data": "The product is an open-end tracker certificate linked to the UBS CMCI Composite USD TR Index, which is a complex commodity index. The use of swaps and the synthetic replication method introduce significant counterparty risk. The product also carries termination risk, where the issuer can terminate the product under certain conditions, potentially leading to a total loss. The risk indicator is 4 out of 7, but the complexity arises from the structure rather than the risk level. The product is not UCITS-compliant, and the KIID explicitly states that it is not simple and may be difficult to understand, which is a strong indicator of complexity under MiFID II.",
    "confidence": 90
}