{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps to achieve its investment objective, which introduces counterparty risk and complexity. The KIID explicitly states that the Fund will use unfunded swaps to exchange the performance of securities held by the Fund for the performance of the reference index. This synthetic replication method, combined with the reliance on counterparties, makes the ETF complex under MiFID II. Additionally, the risk category is 7, indicating higher risk and complexity. The presence of extensive derivative-related risk disclosures and the synthetic ETF risk further support the classification as complex.",
    "confidence": 90
}