{
    "fund_name": "HSBC MSCI INDONESIA UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Total Return Swaps",
        "Contracts for Difference",
        "Emerging Market Concentration"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses derivatives, including total return swaps and contracts for difference (up to 10% of assets), which introduces counterparty risk and potential complexity. Additionally, the fund may invest up to 35% in securities from a single issuer under exceptional conditions, and it tracks an emerging market index with high concentration risk. The KIID explicitly mentions derivative risks and investment leverage risks, which are indicators of complexity under MiFID II. The fund's risk profile is categorized as level 7, indicating very high fluctuations. While the primary replication method is physical, the use of derivatives for purposes beyond efficient portfolio management (e.g., gaining exposure to index constituents) and the potential for significant tracking error contribute to the complexity classification.",
    "confidence": 85,
    "counter_argument": "The fund primarily uses physical replication and is UCITS-compliant, which might suggest it is non-complex. However, the use of derivatives (swaps and CFDs) for gaining exposure to index constituents, even if limited to 10%, introduces elements of complexity that require specialist knowledge to fully understand the risks involved. The high concentration risk and emerging market exposure further support the classification as complex.",
    "risk_level": 7
}