{
    "name": "UBS (Irl) Fund Solutions plc - MSCI ACWI SF UCITS ETF (hedged to USD) A-UKdis",
    "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 a swap agreement with UBS AG as the counterparty, which introduces counterparty risk and complexity beyond physical replication. 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 fact sheet confirms the synthetic replication methodology and the use of collateral (G10 government bonds, supranational bonds, and cash) to mitigate counterparty risk. While the fund does not use leverage or inverse strategies, the reliance on a swap agreement and the associated counterparty risk make it a complex instrument under MiFID II. The risk profile is rated at level 6, indicating higher risk, and the extensive disclosures about counterparty risk further support the complex classification.",
    "confidence": 90,
    "counterparty_risk": true,
    "collateral_management": true,
    "risk_level": 6,
    "benchmark_complexity": "low",
    "liquidity_risk": "moderate",
    "additional_notes": "Although the ETF tracks a well-known, diversified equity index (MSCI ACWI) and does not employ leverage or inverse strategies, the synthetic replication method and the associated counterparty risk are the primary drivers of its complex classification. The use of derivatives (swaps) for replication, even if collateralized, introduces risks that may not be fully understood by retail investors, thus meeting the criteria for complexity under MiFID II."
}