{
    "fund_name": "UBS MSCI Singapore UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Derivative usage for replication",
        "Counterparty risk from OTC derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The KIID and factsheet indicate that while the ETF primarily uses physical replication, it may employ derivatives (including OTC derivatives) when direct investment is impractical or to generate efficiencies. The presence of OTC derivatives introduces counterparty risk, which is a key complexity indicator under MiFID II. Additionally, the fund's risk category of 6 (high volatility) and the use of derivatives for purposes beyond simple replication contribute to the complexity classification. The factsheet confirms the use of derivatives for replication purposes, reinforcing the complexity assessment.",
    "confidence": 85,
    "risk_level": 6,
    "counterparty_risk": true,
    "benchmark_complexity": "low",
    "liquidity_risk": "moderate",
    "additional_notes": "While the ETF is UCITS-compliant and primarily uses physical replication, the documented use of OTC derivatives for replication purposes and the associated counterparty risk are sufficient to classify it as complex under MiFID II. The high risk category (6) further supports this classification, as it indicates significant volatility and potential for substantial losses, which may not be easily understood by retail investors."
}