{
    "fund_name": "Global X Blockchain UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Unfunded OTC Swaps",
        "Blockchain Technology Exposure",
        "High Risk Category (7)"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses 'unfunded' OTC swaps and exchange-traded equity futures for investment purposes, which introduces counterparty risk and complexity. Additionally, the fund's exposure to blockchain technology, a relatively new and volatile sector, combined with its high risk category (7), contributes to its classification as complex. The KIID explicitly mentions the use of financial derivative instruments (FDIs) for investment purposes, which is a key indicator of complexity under MiFID II.",
    "confidence": 0.9,
    "counter_argument": "The ETF primarily uses physical replication and has a straightforward index-tracking objective, which might suggest it is non-complex. However, the use of unfunded swaps and the high-risk nature of blockchain technology exposure override this argument, as these factors introduce significant additional risks and complexities that require specialist knowledge to understand fully.",
    "risk_level": 7,
    "benchmark_complexity": "The Solactive Blockchain v2 Index is complex due to its focus on blockchain technology, which is a rapidly evolving and highly specialized sector. This adds to the overall complexity of the ETF."
}