{
    "fund_name": "Xtrackers MSCI EM Asia Screened Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "ESG Screening Complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swap agreements to track the MSCI Emerging Markets Asia Select Screened Index, which introduces counterparty risk. The KIID explicitly mentions the use of derivatives and swap counterparties, which are key indicators of complexity under MiFID II. Additionally, the ESG screening methodology adds another layer of complexity due to the rules-based exclusions and carbon emission reduction rules. The fund's risk profile is classified as category 6, indicating high volatility and potential for significant losses, further supporting the complex classification.",
    "confidence": 90,
    "counter_argument": "The ETF is UCITS-compliant and provides clear disclosures, which might suggest it is non-complex. However, the use of swaps and the synthetic replication method override this argument, as these features inherently introduce complexity that requires specialist knowledge to fully understand the risks involved.",
    "risk_level": 6
}