{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "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 fund employs an indirect replication methodology through a financial derivative instrument (swap). The presence of counterparty risk and the use of swaps for replication are key indicators of complexity under MiFID II. Additionally, the fund's risk profile includes significant counterparty risk disclosures, which further supports the classification as complex.",
    "confidence": 90,
    "risk_level": 5,
    "benchmark_complexity": "The S&P Global Luxury Index is a straightforward equity index, but the synthetic replication method adds complexity.",
    "counterparty_risk": true,
    "liquidity_risk": "Mentioned as a risk factor, but not a primary driver of complexity.",
    "additional_notes": "While the underlying index is not inherently complex, the use of synthetic replication via swaps and the associated counterparty risk make this ETF complex under MiFID II. The fund's documentation clearly highlights the reliance on derivatives and swaps, which are key triggers for complexity classification."
}