{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swaps",
        "Counterparty Risk"
    ],
    "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 presence of an unfunded swap structure creates additional complexity. While the ETF does not employ leverage or inverse strategies, the reliance on derivatives for replication and the associated counterparty risk make it a complex instrument under MiFID II.",
    "confidence": 90,
    "risk_level": 5,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "benchmark_complexity": false,
    "comprehension_warning": false,
    "additional_notes": "The ETF is UCITS-compliant, which typically suggests a higher level of investor protection, but the use of synthetic replication and derivatives still classifies it as complex under MiFID II. The risk level of 5 further supports this classification due to the inherent risks associated with synthetic replication and emerging market exposure."
}