{
    "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 states that the Fund will use unfunded swaps to exchange the performance of securities held by the Fund for the performance of the reference index. This synthetic replication method, combined with the reliance on counterparties, makes the ETF complex under MiFID II. Additionally, the risk category is 7, indicating higher risk and potential complexity. The presence of extensive derivative-related risk disclosures and the synthetic nature of the replication method further support the classification as complex.",
    "confidence": 90,
    "risk_level": 7,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of swaps and synthetic replication is sufficient to classify it as complex under MiFID II. The fact that the swaps are unfunded adds another layer of complexity due to the potential for counterparty risk. The high risk category (7) and the detailed disclosures about synthetic ETF risks further reinforce this classification."
}