{
    "name": "iShares Edge MSCI Europe Momentum Factor UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Factor-based strategy",
        "Optimized replication",
        "Counterparty risk from derivatives"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication with optimized techniques, including selective security purchases and potential derivative use for efficient portfolio management (EPM) rather than as a core strategy. While derivatives are mentioned, they are not used for leverage or synthetic replication, and the primary strategy is straightforward momentum-based equity exposure. The risk level (6) is high due to equity market risks rather than structural complexity. The fund is UCITS-compliant with clear disclosure of risks and costs.",
    "confidence": 90,
    "counter_argument": "The use of derivatives could be seen as a complexity trigger, but since they are used for EPM and not as a primary strategy, and the fund is physically replicated with a clear momentum factor approach, the overall structure remains understandable for retail investors. The absence of leverage, inverse exposure, or synthetic replication supports the non-complex classification.",
    "risk_level": 6,
    "benchmark_complexity": "The MSCI Europe Momentum Index is a factor-based index, which introduces some complexity due to its methodology, but it is still a transparent and rules-based equity index."
}