{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Frontier market exposure",
        "Counterparty risk"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers S&P Select Frontier Swap UCITS ETF uses synthetic replication via swap agreements to track the S&P Select Frontier Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the use of derivatives and swap counterparties, which are key indicators of complexity under MiFID II. Additionally, the fund's exposure to frontier markets adds another layer of risk and complexity due to the illiquidity and volatility associated with these markets. The presence of counterparty risk and the reliance on derivatives for replication are the primary drivers of the 'complex' classification, even though the fund does not use leverage or inverse strategies.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "illiquid_assets": true,
    "comprehension_warning": "The fund's reliance on derivatives and exposure to frontier markets may not be easily understood by retail investors, further supporting the 'complex' classification."
}