{
    "fund_name": "Avantis Emerging Markets Equity UCITS ETF USD ACC",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Avantis Emerging Markets Equity UCITS ETF is an actively managed fund that invests at least 80% of its NAV in equities and equity-related securities from emerging markets. It does not use synthetic replication, leverage, or derivatives as part of its core strategy. The fund explicitly states it does not invest in contingent convertible bonds and avoids complex structured products. The risk profile is rated at 6, which is relatively high but not due to structural complexity. The fund's strategy is straightforward, focusing on direct equity investments without embedded derivatives or complex financial instruments. The KIID does not mention any use of swaps, leverage, or inverse strategies, and the fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II.",
    "confidence": 95,
    "risk_level": 6,
    "counter_argument": "While the fund has a high risk rating (6), this is primarily due to the inherent risks of emerging markets rather than structural complexity. The absence of derivatives, leverage, or synthetic replication supports the non-complex classification. The fund's active management and geographic focus do not introduce complexity under MiFID II criteria."
}