{
    "fund_name": "KraneShares CSI China Internet UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The KraneShares CSI China Internet UCITS ETF is a physically replicated ETF that tracks the CSI Overseas China Internet Index. It does not use derivatives, swaps, or leverage, and its replication method is straightforward physical replication. The fund's risk profile is high (category 7) due to its exposure to Chinese internet companies, but this is a function of the underlying assets rather than structural complexity. The fund's documentation explicitly states it does not intend to use financial derivative instruments, and its primary risks are related to equity exposure, emerging markets, and concentration risk, which are typical for sector-specific ETFs. The fund is UCITS-compliant, which imposes additional investor protection requirements, further supporting its non-complex classification.",
    "confidence": 95,
    "counter_argument": "Some might argue that the high risk rating (category 7) or the exposure to emerging markets could indicate complexity. However, under MiFID II, complexity is more about the structure and transparency of the investment rather than the volatility or risk level of the underlying assets. The fund's physical replication and lack of derivative usage outweigh the risk rating in this assessment.",
    "risk_level": 7
}