{
    "fund_name": "Global X Genomics & Biotechnology UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Unfunded OTC swaps",
        "High risk category (7)",
        "Concentration risk in biotech sector"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but may employ 'unfunded' OTC swaps and equity futures for investment purposes, which introduces counterparty risk and complexity. The risk category is 7 (highest), indicating significant volatility. The fund's concentration in genomics and biotechnology companies adds sector-specific risks. While derivatives are used for hedging and efficient portfolio management, the presence of OTC swaps and the high-risk profile contribute to the complexity classification under MiFID II.",
    "confidence": 85,
    "counter_argument": "The ETF is UCITS-compliant and primarily uses physical replication, which typically suggests non-complex status. However, the use of OTC swaps and the high-risk profile override this, as MiFID II considers counterparty risk and volatility as key complexity indicators.",
    "risk_level": 7,
    "benchmark_complexity": "The Solactive Genomics v2 Index is sector-specific and may include companies with high volatility and research-dependent valuations, adding to complexity."
}