{
    "fund_name": "UBS (Irl) Fund Solutions plc - MSCI ACWI SF UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via financial derivative instruments (FDIs) with UBS AG as the counterparty, which introduces counterparty risk. The KIID explicitly states that the Fund's performance is swapped from UBS to the Fund, and the Fund's performance reflects the Index rather than the underlying securities. The presence of swap agreements and counterparty risk, along with the synthetic replication method, are key indicators of complexity under MiFID II. Additionally, the risk profile is rated at level 6, indicating higher risk, and the KIID mentions extensive counterparty risk disclosures. The fact sheet confirms the use of a fully funded total return swap, further reinforcing the synthetic nature of the replication.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "benchmark_complexity": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the synthetic replication and counterparty risk exposure are sufficient to classify it as complex under MiFID II. The use of derivatives is not merely for efficient portfolio management but is central to the replication strategy, which introduces additional risks that may not be easily understood by retail investors."
}