{
    "fund_name": "Tabula ICAV - Janus Henderson Tabula Japan High Conviction Equity UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a physically replicated, actively managed equity fund with a concentrated portfolio of 20-30 Japanese equities. Derivatives are only used for hedging/risk reduction (e.g., forward FX contracts for currency hedging), not for synthetic replication or leverage. The fund has no leverage, inverse exposure, or complex underlying assets. The risk profile (rated 6) is primarily due to concentration risk rather than structural complexity. The fund is UCITS-compliant, providing additional investor protections and transparency.",
    "confidence": 95,
    "counter_argument": "The fund's concentrated portfolio (20-30 holdings) and active management could be seen as introducing complexity. However, this is outweighed by the physical replication, lack of leverage, and straightforward equity strategy. The use of derivatives is explicitly limited to hedging purposes, which does not trigger complexity under MiFID II.",
    "risk_level": "The fund's risk rating of 6 is driven by market and concentration risks typical of an actively managed equity fund, not by structural complexity or derivative exposure."
}