{
    "fund_name": "Tabula ICAV - Tabula GCC Sovereign USD Bonds UCITS ETF",
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication via a sampling strategy to track the ICE Gulf Cooperation Council Government Bond ex-144a Index. It invests directly in USD-denominated sovereign bonds and Sukuks issued by GCC members, with no mention of synthetic replication, swaps, or derivative instruments. The risk profile (rated 4) is primarily driven by credit, liquidity, and emerging market risks inherent to the asset class rather than structural complexity. The KIID explicitly states the product is not simple but may be difficult to understand, which is a standard disclosure for bond ETFs rather than an indicator of MiFID II complexity. The factsheet confirms direct replication and no derivative usage beyond standard portfolio management.",
    "confidence": 95,
    "counter_argument": "The KIID includes a warning that the product may be difficult to understand, which could suggest complexity. However, this is a standard disclosure for bond ETFs and does not indicate structural complexity under MiFID II. The absence of derivatives, leverage, or synthetic replication outweighs this warning.",
    "risk_level": "The ETF has a risk rating of 4 due to credit, liquidity, and emerging market risks, but these are inherent to the asset class and do not stem from structural complexity."
}