{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivative instruments. The KIID explicitly states that the Fund will use unfunded swaps to exchange the performance of a basket of equities for the performance of the MSCI Kuwait 20/35 Index. This synthetic replication method, combined with the risks associated with counterparty exposure and the potential for tracking error due to swap pricing discrepancies, makes the product complex under MiFID II. Additionally, the risk category is rated at level 6, indicating higher risk, and the documentation highlights the reliance on derivatives for index tracking, which further supports the complex classification.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "illiquid_assets": false,
    "structured_products": false,
    "capital_protection": false,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of synthetic replication via unfunded swaps is a key factor in classifying it as complex. The reliance on derivatives for tracking the index, combined with counterparty risk, aligns with MiFID II criteria for complex instruments. The absence of a comprehension warning in the PRIIPs KID does not override the inherent complexity introduced by the swap agreements."
}