{
    "fund_name": "Invesco STOXX Europe 600 Optimised Telecommunications UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly mentions the use of swap agreements to exchange the performance of securities held by the fund for the performance of the reference index. Additionally, the fund is classified as a synthetic ETF, which typically involves more complex structures compared to physical replication. The risk category is 6, indicating higher risk, and the fund's performance is reliant on counterparties delivering the benchmark performance as per the swap agreements. The presence of synthetic replication and swap agreements are key indicators of complexity under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "capital_protection": false,
    "structured_features": false,
    "underlying_asset_complexity": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of swaps and synthetic replication methods are sufficient to classify it as complex under MiFID II. The fund's reliance on counterparties for performance delivery and the associated risks further support this classification."
}