{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk",
        "Emerging market exposure"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers MSCI Pakistan Swap UCITS ETF uses synthetic replication via swap agreements to track the MSCI Pakistan Investable Market Total Return Net Index. The KIID explicitly states that the fund enters into financial contracts (derivatives) with swap counterparties, which introduces counterparty risk. The fund's risk profile is rated at level 6, indicating high volatility. Additionally, the fund is exposed to frontier market risks, which are inherently complex due to political and economic instability. The use of swaps and the associated counterparty risk, combined with the complexity of the underlying market, make this ETF complex under MiFID II regulations.",
    "confidence": 90
}