{
    "fund_name": "Xtrackers S&P 500 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"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps to track the S&P 500 Index, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions the use of derivatives and swap agreements, highlighting counterparty risk as a significant factor. While the ETF does not employ leverage or inverse strategies, the reliance on swaps for replication and the associated risks (e.g., counterparty insolvency) make it complex under MiFID II. The risk profile is classified as category 6, indicating high potential for fluctuations and losses, further supporting the complexity classification.",
    "confidence": 90,
    "counterparty_risk": true,
    "risk_profile": 6,
    "benchmark_complexity": "low",
    "liquidity_risk": "moderate",
    "additional_notes": "The ETF is UCITS-compliant and does not use leverage or inverse strategies, but the synthetic replication method via swaps is the primary driver of its complexity classification. The factsheet confirms the use of indirect replication (swap-based), reinforcing the assessment."
}