{
    "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 synthetic replication via financial derivative instruments (FDIs) with UBS AG as the counterparty, which introduces counterparty risk and complexity. The KIID explicitly mentions the use of swap agreements and the potential impact of counterparty failure. Additionally, the risk profile is rated at level 6, indicating higher volatility and complexity. The fact sheet confirms the use of a fully funded swap structure, which, while mitigating some risks, still introduces complexity through derivative exposure and counterparty risk.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "capital_protection": false,
    "illiquid_assets": false,
    "structured_features": false,
    "comprehension_warning": false,
    "additional_notes": "The ETF is classified as complex primarily due to its synthetic replication method and the associated counterparty risk. While the ETF does not use leverage or inverse strategies, the reliance on derivatives and swaps for replication introduces elements that may not be easily understood by retail investors, thus meeting the criteria for complexity under MiFID II."
}