{
    "name": "Xtrackers FTSE Vietnam Swap UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk",
        "Emerging market exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the FTSE Vietnam Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions derivative usage for index tracking and highlights counterparty risk as a significant factor. The fund's risk profile is rated at level 6, indicating high volatility and complexity. The presence of swap agreements and the reliance on derivative instruments for replication are key factors in classifying this as a complex product under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "emerging_market_risk": true,
    "liquidity_risk": true,
    "tracking_error_risk": true,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the synthetic replication method and the associated counterparty risks are sufficient to classify it as complex under MiFID II. The fund's exposure to Vietnamese equities, which are less liquid and more volatile, further contributes to its complexity."
}