{
    "fund_name": "Invesco MSCI Japan UCITS ETF",
    "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 ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on the performance of derivatives. The KIID explicitly mentions 'Synthetic ETF Risk' and highlights the dependency on counterparties to deliver the benchmark performance. The risk category is 6, indicating higher risk, and the document emphasizes the potential financial loss due to counterparty insolvency. The use of synthetic replication and swaps, even if unfunded, qualifies the ETF as complex under MiFID II due to the inherent risks and the need for investors to understand the mechanics of swaps and counterparty exposure.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "benchmark_complexity": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the reliance on swaps and synthetic replication is sufficient to classify it as complex. The PRIIPs document and factsheet reinforce the use of swaps and the associated risks, further supporting the complex classification."
}