{
    "name": "Global X Cybersecurity 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"
    ],
    "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 is 7, indicating high volatility, and the fund's concentration in cybersecurity equities adds to its complexity. The presence of derivative-related risks and counterparty exposure further supports the classification as complex.",
    "confidence": 0.9,
    "counter_argument": "The fund is UCITS-compliant and primarily uses physical replication, which might suggest non-complexity. However, the use of unfunded swaps and derivatives for investment purposes (not just hedging) overrides this, as such strategies require specialist knowledge to fully understand the risks involved.",
    "risk_level": 7,
    "benchmark_complexity": "The Indxx Cybersecurity v2 Index is sector-specific and may involve complex weighting methodologies, but this alone does not drive the complexity classification. The derivative usage is the primary factor."
}