{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Machine Learning Strategy"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses total return swaps to synthetically replicate the performance of a portfolio of equities selected via a machine learning algorithm. This introduces counterparty risk and complexity due to the derivative exposure. Additionally, the use of machine learning for stock selection adds a layer of complexity that may not be easily understood by retail investors. The KIID explicitly mentions counterparty risk and derivative exposure, which are key indicators of complexity under MiFID II.",
    "confidence": 90
}