{
    "fund_name": "Global X E-commerce 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 explicitly states the fund may use 'unfunded' OTC swaps and financial derivative instruments (FDIs) for investment purposes, which introduces counterparty risk and complexity beyond standard physical replication. While the primary method is physical replication, the use of derivatives for purposes other than efficient portfolio management (EPM) triggers complexity under MiFID II. The fund's high risk rating (7/7) and exposure to concentrated e-commerce sectors further support this classification.",
    "confidence": 0.9,
    "counter_argument": "The fund primarily uses physical replication and does not employ leverage or inverse strategies, which could argue for a non-complex classification. However, the explicit mention of 'unfunded' OTC swaps and FDIs for investment purposes (not just hedging) overrides this, as such instruments introduce material counterparty and operational risks that require specialist knowledge to fully understand.",
    "risk_level": 7,
    "benchmark_complexity": "The Solactive E-commerce v2 Index is sector-specific but not inherently complex in structure. However, the fund's use of derivatives to track it adds layers of risk that may not be immediately apparent to retail investors."
}