{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Currency hedging using FX forwards",
        "Use of financial derivative instruments for direct investment purposes"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses financial derivative instruments (FDIs) including FX forward contracts for currency hedging purposes, which introduces counterparty risk and complexity beyond simple physical replication. While the primary replication method is physical, the use of derivatives for hedging and potential direct investment purposes, along with the mention of counterparty risk in the KIID, suggests elements of complexity under MiFID II. The presence of these derivative instruments, even if used for hedging, can classify the product as complex due to the additional risks and mechanisms involved.",
    "confidence": 85,
    "risk_level": 1,
    "counterparty_risk": true,
    "credit_risk": true,
    "liquidity_risk": false,
    "benchmark_complexity": false,
    "additional_notes": "Although the ETF is physically replicated and tracks a straightforward government bond index, the use of derivatives for hedging and potential direct investment introduces complexity. The KIID explicitly mentions counterparty risk and the use of FDIs, which are key indicators of complexity under MiFID II. The low risk level (1) does not negate the complexity introduced by derivative usage."
}