{
    "fund_name": "Global X Cloud Computing 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 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 risk profile (category 7) and explicit mention of derivatives risk further support this classification.",
    "confidence": 85,
    "counter_argument": "The fund primarily uses physical replication and is UCITS-compliant, which typically suggests non-complex status. However, the explicit use of unfunded swaps and derivatives for investment purposes (not just hedging) overrides this, as such instruments introduce additional risks that may not be easily understood by retail investors.",
    "risk_level": 7,
    "benchmark_complexity": "The Indxx Global Cloud Computing v2 Index is sector-specific and may involve higher volatility, but this alone does not drive complexity. The derivative usage is the primary factor."
}