{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and reliance on derivative instruments. The KIID explicitly mentions the use of swap agreements and the risks associated with synthetic replication, including the potential insolvency of counterparties. The risk category is 6, indicating higher risk, and the document highlights the complexity of the synthetic replication method. The presence of swap fees and the reliance on derivatives for tracking the index further contribute to the complexity.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and aims to track a well-known index, which might suggest simplicity. However, the use of swaps and the associated counterparty risks, as well as the synthetic replication method, outweigh this argument, making the ETF complex under MiFID II rules.",
    "risk_level": 6
}