{
    "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 6, indicating higher risk, and the document highlights risks associated with synthetic ETFs and counterparty exposure.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "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 it is UCITS compliant does not override the complexity introduced by the synthetic replication and counterparty risk."
}