{
    "name": "iShares NASDAQ 100 Swap UCITS ETF USD (Acc)",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Unfunded Total Return Swaps",
        "Counterparty Risk",
        "Derivative Exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded total return swaps to achieve its investment objective, which introduces counterparty risk and derivative exposure. The KIID explicitly mentions the use of financial derivative instruments and the risks associated with them, including the potential for greater fluctuations in the fund's value due to derivative sensitivity. The risk indicator is rated at level 6, which is relatively high, and the document highlights significant counterparty risk and the reliance on swap agreements for performance tracking. The use of synthetic replication via swaps and the associated risks make this a complex instrument under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "benchmark_complexity": "low",
    "liquidity_risk": "medium",
    "additional_notes": "While the ETF tracks a well-known index (NASDAQ 100) and is UCITS compliant, the use of synthetic replication via unfunded swaps introduces complexity that requires investors to understand counterparty risk and derivative mechanics. The high risk rating and explicit warnings about derivative risks further support the classification as complex."
}