{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk",
        "Indirect Replication"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via a total return swap, which introduces counterparty risk and derivative exposure. The KIID explicitly states that derivatives are integral to the investment strategy, and the factsheet confirms the replication type as synthetic. While the ETF tracks a straightforward equity index, the use of unfunded swaps and the associated counterparty risk make it complex under MiFID II rules. The risk profile (SRRI 4) and the presence of liquidity and operational risks further support this classification.",
    "confidence": 90,
    "counter_argument": "The ETF tracks a well-known equity index and has a relatively low risk profile (SRRI 4). However, the use of synthetic replication via swaps and the explicit mention of counterparty risk in the KIID override these factors, as MiFID II explicitly flags synthetic replication and significant derivative usage as complexity indicators.",
    "risk_level": 4
}