{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly states that the Fund will use swaps to exchange the performance of securities held for the performance of the reference index, indicating synthetic replication. Additionally, the risk profile is categorized as level 6, which is relatively high, and there are extensive disclosures about derivative-related risks and counterparty exposure. The presence of synthetic replication and the associated risks make this ETF complex under MiFID II regulations.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "capital_protection": false,
    "illiquid_assets": false,
    "structured_features": false,
    "benchmark_complexity": false,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or invest in illiquid assets, the use of swaps and synthetic replication is sufficient to classify it as complex under MiFID II. The high risk level (6) and the detailed disclosures about counterparty risk further support this classification."
}