{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Synthetic Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an over-the-counter swap contract (FDI) with counterparties like Morgan Stanley Bank AG and Societe Generale, exposing investors to counterparty risk. The KIID explicitly mentions risks associated with financial derivative instruments, including leverage risk, high volatility, and liquidity risk. The factsheet confirms the use of an OTC swap for replication, which is a key complexity indicator under MiFID II. While the ETF does not employ leverage or inverse strategies, the reliance on swaps and the associated counterparty risks make it complex. The SRRI risk level is moderate, but the synthetic structure and derivative usage override this in the complexity assessment.",
    "confidence": 90
}