{
    "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 iShares MSCI USA Swap UCITS ETF uses unfunded total return swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivatives. The KIID explicitly states that the fund invests in financial derivative instruments (FDIs), particularly unfunded total return swaps, to track the MSCI USA Index. The presence of significant counterparty risk and the synthetic replication method are key indicators of complexity under MiFID II. Additionally, the risk profile is rated as 6 out of 7, indicating higher risk, which often correlates with complexity. The fund's reliance on swaps and the associated risks, such as the potential for counterparty failure and tracking error, further support the classification as a complex instrument.",
    "confidence": 95
}