{
    "fund_name": "UBS (Irl) Fund Solutions plc - MSCI ACWI SF UCITS ETF (hedged to EUR) A-acc",
    "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 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 the performance swap structure, where the index performance is swapped from UBS to the fund. The presence of counterparty risk and the synthetic replication method are key indicators of complexity under MiFID II. Additionally, the fund's risk profile is rated at level 6, indicating higher risk and potential complexity. The fact sheet confirms the use of a fully funded total return swap, further reinforcing the synthetic nature of the replication.",
    "confidence": 90,
    "counterparty_risk": true,
    "risk_level": 6,
    "benchmark_complexity": "The MSCI ACWI Net Total Return Index is a broad, well-diversified equity index, but the synthetic replication and swap structure add layers of complexity beyond the underlying benchmark.",
    "additional_notes": "While the ETF itself does not employ leverage or inverse strategies, the use of synthetic replication and the associated counterparty risk are sufficient to classify it as complex under MiFID II. The fund's documentation clearly outlines these risks, which are not present in physically replicated ETFs."
}