{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Currency Hedging"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via an OTC swap contract with counterparties (Morgan Stanley Bank AG, Societe Generale), which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly mentions financial derivative instruments (FDIs) and the risks associated with them, including leverage risk, high volatility risk, and liquidity risk. The fact sheet confirms the use of an unfunded swap structure, which is a key indicator of complexity under MiFID II. Additionally, the currency hedging strategy adds another layer of complexity, as it involves monthly adjustments to offset currency fluctuations. While the ETF does not use leverage or inverse strategies, the reliance on derivatives for replication and hedging, combined with counterparty exposure, meets the criteria for classification as a complex instrument.",
    "confidence": 90,
    "risk_level": "The ETF has a risk rating of 4-5, which aligns with its synthetic replication and derivative usage, further supporting the complex classification."
}