{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Total Return Swaps",
        "Counterparty Risk",
        "Synthetic 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 synthetic replication method. While the ETF does not use leverage or inverse strategies, the reliance on 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": "Some may argue that synthetic ETFs with straightforward swap structures are widely understood and traded, thus not necessarily complex. However, MiFID II explicitly flags synthetic replication and counterparty risk as complexity indicators, overriding this argument.",
    "risk_level": 4
}