{
    "fund_name": "iShares MSCI USA Momentum Factor Advanced UCITS ETF USD (Acc)",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Factor-based index complexity",
        "ESG optimization constraints"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the MSCI USA Momentum Advanced Select Index, which is a factor-based index with ESG constraints. While the KIID mentions the potential use of financial derivative instruments (FDIs), it specifies these are used to help achieve the investment objective rather than as a core strategy. The fund does not employ leverage, inverse strategies, or synthetic replication. The risk rating of 6 is primarily due to equity market risks rather than structural complexity. The ESG optimization and momentum factor focus add some complexity to the index methodology, but this is disclosed transparently. The fund's physical replication approach and lack of material derivative exposure keep it within non-complex parameters under MiFID II.",
    "confidence": 85,
    "counter_argument": "Some might argue the factor-based index and ESG optimization could make this complex, but these are increasingly common in mainstream ETFs and are clearly disclosed. The derivative usage is limited to EPM purposes rather than being a fundamental part of the strategy.",
    "risk_level": 6,
    "esg_focus": true,
    "factor_based": true,
    "securities_lending": true,
    "benchmark_complexity": "moderate"
}