{
    "fund_name": "ESG Value Europe",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a substitute basket of securities, where performance is swapped with the index, introducing counterparty risk. The KIID explicitly mentions 'synthetic replication' and 'counterparty risk,' which are key indicators of complexity under MiFID II. While the fund does not employ leverage or inverse strategies, the use of swaps and the associated counterparty risk make it complex. The risk profile is rated at level 5, which aligns with the complexity assessment. The fund's ESG focus does not mitigate the complexity introduced by the synthetic replication method.",
    "confidence": 90,
    "risk_level": 5,
    "counterparty_risk": true,
    "benchmark_complexity": "moderate",
    "liquidity_risk": "moderate",
    "additional_notes": "The fund's use of synthetic replication and the explicit mention of counterparty risk in the KIID are the primary drivers of the 'complex' classification. While the fund is UCITS-compliant and does not use leverage, the synthetic structure and associated risks are sufficient to classify it as complex under MiFID II."
}