{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers Stoxx Global Select Dividend 100 Swap UCITS ETF uses synthetic replication via swap agreements to track its index, which introduces counterparty risk and derivative exposure. The KIID explicitly mentions the use of financial contracts (derivatives) with swap counterparties to obtain the index return, indicating a synthetic replication method. The presence of counterparty risk and the reliance on derivatives for replication are key factors that classify this ETF as complex under MiFID II. Additionally, the fund's risk level is classified as category 6, indicating high potential for price fluctuations and significant risk exposure. While the fund does not employ leverage or inverse strategies, the synthetic replication and associated counterparty risks are sufficient to warrant a complex classification.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "underlying_assets": "Equities with high dividend yields",
    "benchmark_complexity": "Rules-based dividend index with potential concentration risks",
    "additional_notes": "The fund's use of swaps for replication, while common in synthetic ETFs, introduces complexity due to the need for investors to understand counterparty risk and the mechanics of swap agreements. The high risk rating (category 6) further supports the complex classification, as it indicates significant potential for volatility and loss."
}