{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Commodity Futures",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers Bloomberg Commodity ex-Agriculture & Livestock Swap UCITS ETF uses synthetic replication via swaps to track its underlying index, which consists of commodity futures. The KIID explicitly mentions the use of derivatives and swaps to achieve its investment objective, along with significant counterparty risk exposure. The fund's risk profile is rated at level 6, indicating high volatility and complexity. The presence of swap agreements and the potential for counterparty risk, combined with the complexity of commodity futures and the synthetic replication method, make this a complex instrument under MiFID II. While the fund does not use leverage or inverse strategies, the reliance on derivatives for replication and the inherent risks associated with commodity futures and swaps are sufficient to classify it as complex.",
    "confidence": 90
}