{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity beyond standard physical replication. The KIID explicitly states the use of swaps to exchange performance with a counterparty, which is a key indicator of complexity under MiFID II. Additionally, the risk profile (category 6) and the synthetic replication method contribute to the classification as complex. While the ETF does not use leverage or inverse strategies, the reliance on swaps and the associated counterparty risk make it complex.",
    "confidence": 90
}