{
    "name": "Vanguard FTSE Emerging Markets UCITS (USD) Accumulating",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication to track the FTSE Emerging Markets Index, primarily investing directly in the underlying securities. While it may use derivatives for efficient portfolio management (e.g., reducing risk or cost), this does not introduce complexity under MiFID II as it is not a core part of the investment strategy. The fund does not employ leverage, inverse strategies, or synthetic replication. The risk profile is transparent, with a clear focus on emerging market equities, and the ongoing charges are straightforward. The KIID and factsheet provide adequate information for retail investors to understand the product.",
    "confidence": 95,
    "risk_level": 6,
    "counterparty_risk": "The fund acknowledges counterparty risk from derivatives used for EPM, but this is a standard disclosure and does not indicate complexity.",
    "liquidity_risk": "The fund invests in emerging markets, which may have lower liquidity, but this is a characteristic of the asset class rather than a structural complexity.",
    "additional_notes": "The ETF is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II. The use of derivatives is limited to risk management and cost reduction, not as a primary investment strategy, reinforcing the non-complex classification."
}