{
    "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 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 a basket of equities for the performance of the MSCI Europe ex UK Index. This synthetic replication method, combined with the reliance on counterparties, makes the product complex under MiFID II rules. Additionally, the risk category is 6, indicating higher risk, and the document highlights risks associated with synthetic ETFs and derivative usage.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "comprehension_warning": false,
    "benchmark_complexity": "low",
    "liquidity_risk": "low",
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the use of unfunded swaps and synthetic replication introduces complexity due to counterparty risk and the need for investors to understand the mechanics of swap agreements. The PRIIPs KID and factsheet reinforce the synthetic nature of the ETF and the associated risks, further supporting the classification as complex."
}