{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a swap agreement with UBS AG as the counterparty, which introduces counterparty risk and complexity. The KIID explicitly mentions the use of financial derivative instruments (FDIs) and swap agreements, which are key indicators of complexity under MiFID II. The swap is described as a total return swap, and the fund's performance is directly tied to the counterparty's ability to fulfill the swap terms. Additionally, the risk profile is rated at level 6, indicating higher risk, and the fund's main risk is identified as counterparty risk. The fact sheet confirms the synthetic replication methodology and the use of collateral, further supporting the complexity classification.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and has a straightforward investment objective of tracking the MSCI ACWI Index, which could suggest it is non-complex. However, the use of synthetic replication and the associated counterparty risk outweigh this argument, as MiFID II explicitly flags synthetic replication and significant counterparty exposure as complexity indicators.",
    "risk_level": 6
}