{
    "fund_name": "Global X U.S. Infrastructure Development UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Unfunded OTC swaps",
        "Financial derivative instruments for investment purposes"
    ],
    "classification": "complex",
    "supporting_data": "The KIID indicates the fund may use 'unfunded' OTC swaps and exchange-traded equity futures for investment purposes, which introduces counterparty risk and complexity beyond simple physical replication. While the primary strategy is physical replication, the explicit mention of derivative usage for purposes beyond efficient portfolio management (EPM) triggers complexity under MiFID II. The risk category of 6 also suggests higher volatility and potential complexity in the underlying strategy.",
    "confidence": 85,
    "counter_argument": "The fund is primarily physically replicated and UCITS-compliant, which typically suggests non-complex classification. However, the explicit use of derivatives for investment purposes (not just hedging or EPM) and the high risk rating (6) outweigh this, as MiFID II considers such features to require specialist knowledge.",
    "risk_level": 6,
    "benchmark_complexity": "The Indxx U.S. Infrastructure Development v2 Index is sector-specific and may involve concentrated exposures, but this alone does not drive complexity. The derivative usage is the primary factor."
}