{
    "fund_name": "UBS (Irl) Fund Solutions plc - MSCI ACWI SF UCITS ETF (hedged to CHF) A-acc",
    "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 the reliance on a counterparty for performance delivery are key indicators of complexity under MiFID II. Additionally, the risk profile is rated at level 6, indicating higher risk, and the KIID highlights counterparty risk as a significant concern. The factsheet confirms the use of a fully funded total return swap, further reinforcing the synthetic nature of the replication method.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and tracks a well-known, diversified equity index, which might suggest it is straightforward. However, the use of synthetic replication and the associated counterparty risk outweigh these factors, as MiFID II explicitly flags synthetic replication and significant counterparty exposure as complexity indicators.",
    "risk_level": 6,
    "additional_notes": "The ETF is hedged to CHF, which adds a layer of complexity due to currency risk management. The factsheet also mentions that the swap counterparty transfers collateral, which is a typical feature of synthetic ETFs but does not mitigate the complexity introduced by the swap structure itself."
}