{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The UBS (Irl) ETF plc - MSCI USA hedged to EUR UCITS ETF is a physically replicated ETF that tracks the MSCI USA 100% hedged to EUR Index. The KIID and factsheet indicate that the fund primarily uses physical replication to mirror the index, holding the underlying securities directly. While the KIID mentions that the fund may use derivatives for risk reduction, cost efficiency, or generating additional income, this usage is limited to efficient portfolio management (EPM) and does not constitute a primary strategy. The fund does not employ leverage, inverse strategies, or synthetic replication. The risk profile is categorized as level 6 due to the volatility of equities, but this is typical for equity ETFs and does not inherently indicate complexity under MiFID II. The fund is UCITS-compliant, which further supports its classification as non-complex. The absence of complex underlying assets, structured features, or capital protection mechanisms reinforces this assessment.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives, even for EPM, could introduce complexity. However, MiFID II guidelines explicitly allow for derivatives in EPM without classifying the instrument as complex, provided the risks remain transparent and the strategy is straightforward. The fund's clear physical replication strategy and lack of leverage or synthetic exposure override this concern.",
    "risk_level": 6
}