{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco FTSE 100 UCITS ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivative instruments. The KIID explicitly states that the fund enters into swap agreements to exchange the performance of its held securities for the performance of the FTSE 100 Index, a hallmark of synthetic replication. Additionally, the risk profile is rated at level 6, indicating higher complexity and risk. The presence of synthetic replication and the associated counterparty risks are key factors in classifying this ETF as complex under MiFID II. The fund's reliance on derivatives for tracking the index, rather than physical replication, further supports this classification.",
    "confidence": 95
}