{
    "fund_name": "Xtrackers S&P Global Infrastructure 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 exposure",
        "Synthetic replication using derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swap agreements to track the S&P Global Infrastructure Index, which introduces counterparty risk and derivative exposure. The KIID explicitly mentions the use of derivatives and swap counterparties, stating that the fund 'will invest in transferable securities and enter into financial contracts (derivatives) with one or more swap counterparties.' Additionally, the risk profile is classified as category 6, indicating high potential for volatility and losses. The presence of counterparty risk and the synthetic replication method are key factors that classify this ETF as complex under MiFID II.",
    "confidence": 90,
    "counter_argument": "The ETF does not use leverage or inverse strategies, and its underlying assets are relatively straightforward (global infrastructure stocks). However, the use of swaps and the associated counterparty risk, along with the synthetic replication method, outweigh these factors, making the ETF complex under MiFID II rules.",
    "risk_level": 6,
    "additional_notes": "The PRIIPs KID and factsheet reinforce the complexity classification by highlighting the derivative usage and counterparty risk. The factsheet explicitly states 'Indirect Replication (Swap)' as the portfolio methodology, confirming the synthetic nature of the ETF."
}