{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for non-EPM purposes",
        "Specialized sector exposure (blockchain/crypto)",
        "High volatility risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its derivative usage beyond efficient portfolio management (EPM) and its exposure to a highly specialized and volatile sector (blockchain/cryptocurrency). While it uses physical replication, the KIID explicitly states that financial derivative instruments (FDIs) may be used for direct investment purposes, not just hedging or EPM. The high risk rating (7/7) and warnings about volatility, counterparty risk, and the niche nature of blockchain technology further support this classification. The PRIIPs KID and factsheet reinforce these concerns with additional warnings about the sector's risks and the fund's concentrated exposure.",
    "confidence": 85,
    "counter_argument": "The ETF could be argued as non-complex because it primarily uses physical replication and is UCITS-compliant. However, the explicit mention of derivatives for direct investment (not just EPM) and the specialized, high-risk nature of the blockchain sector override this argument. The high risk rating and sector-specific risks make it unsuitable for retail investors without specialized knowledge.",
    "risk_level": 7
}