{
    "fund_name": "UBS MSCI Switzerland 20/35 UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Currency Hedging via Derivatives",
        "Potential Use of OTC Derivatives"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but explicitly mentions the use of derivatives, particularly for currency hedging and in cases where direct investment is impractical. The KIID highlights counterparty risk from OTC derivatives, which introduces complexity. While the fund is UCITS-compliant and has a straightforward equity index-tracking objective, the use of derivatives for purposes beyond simple efficient portfolio management (EPM) and the explicit mention of counterparty risks suggest it meets the criteria for complexity under MiFID II. The risk category of 5 further supports this classification due to the elevated risk profile associated with derivative usage.",
    "confidence": 85,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication method and UCITS compliance. However, the explicit use of derivatives for currency hedging and the mention of OTC derivative risks override this argument, as these factors introduce additional layers of risk and complexity that retail investors may not fully comprehend.",
    "risk_level": 5,
    "additional_notes": "The ETF's use of derivatives is not limited to EPM, as it includes currency hedging and potential OTC derivative exposure, which are not straightforward for retail investors. The presence of counterparty risk and the fund's high-risk category (5) further justify the 'complex' classification."
}