{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "FX forward contracts",
        "Counterparty risk from derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses FX forward contracts for currency hedging, which are derivative instruments. While the primary replication method is physical, the use of derivatives for hedging purposes introduces complexity, particularly due to counterparty risk. The KIID explicitly mentions 'counterparty risk' related to derivatives, which is a key indicator of complexity under MiFID II. Additionally, the fund's use of financial derivative instruments (FDIs) for direct investment purposes further supports the classification as complex.",
    "confidence": 85,
    "risk_level": 4,
    "additional_notes": "Although the ETF is physically replicated and does not use leverage or inverse strategies, the use of derivatives for hedging and direct investment purposes, along with the explicit mention of counterparty risk, aligns with MiFID II criteria for complexity. The fund's risk level of 4 also suggests a higher level of risk that may not be easily understood by all retail investors."
}