{
    "fund_name": "Invesco JPX-Nikkei 400 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Unfunded Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the reliance on swap agreements and counterparty performance, which are key indicators of complexity under MiFID II. Additionally, the risk category of 6 and the synthetic replication method further support this classification.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "underlying_assets": "Japanese equities",
    "benchmark_complexity": "The JPX-Nikkei 400 Index is a broad-based index but does not inherently add complexity beyond the synthetic replication method.",
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of unfunded swaps and the synthetic replication method are sufficient to classify it as complex under MiFID II. The PRIIPs KID and factsheet reinforce the reliance on derivatives and counterparty risk, which are critical factors in this determination."
}