{
    "fund_name": "Global X FinTech 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 (FDIs)"
    ],
    "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. While the primary replication method is physical, the use of derivatives for purposes beyond efficient portfolio management (EPM) triggers complexity under MiFID II. The risk category of 7 and explicit mention of derivatives risk further support this classification.",
    "confidence": 85,
    "counter_argument": "The fund is UCITS-compliant and primarily uses physical replication, which might suggest non-complex status. However, the explicit mention of 'unfunded' OTC swaps and FDIs for investment purposes (not just hedging) overrides this, as such instruments introduce material counterparty risk and require specialist knowledge to understand.",
    "risk_level": 7,
    "benchmark_complexity": "Thematic FinTech index with potential illiquidity in underlying components",
    "additional_notes": "The PRIIPs KID and factsheet were not provided, but the KIID alone contains sufficient evidence of derivative usage beyond EPM to classify this as complex. The high risk rating (7) and lack of capital protection further reinforce this determination."
}