{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly states the use of derivatives (swaps) and highlights risks associated with counterparty exposure. While the ETF does not employ leverage or inverse strategies, the synthetic replication method and reliance on swap agreements for performance tracking make it complex under MiFID II. The risk category of 6 further supports this classification due to the additional risks introduced by the synthetic structure.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": false,
    "benchmark_complexity": "The MSCI Europe Index is a standard, well-established equity index and does not contribute to complexity."
}