{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "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 and the associated risks, including the potential insolvency of counterparties. Additionally, the ETF is classified as a synthetic replication fund, which typically involves more complex structures compared to physical replication. The risk category is 6, indicating higher risk and potential complexity. The presence of swap fees and the reliance on counterparties for performance delivery further contribute to the complexity.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "structured_features": false,
    "capital_protection": false,
    "illiquid_assets": false,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of swaps and synthetic replication methods inherently introduces complexity due to the need for investors to understand counterparty risk and the mechanics of swap agreements. The ETF's risk profile and the explicit mention of derivative-related risks in the KIID support the classification as a complex instrument under MiFID II."
}