{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Currency Hedging",
        "OTC Swaps with Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses physical replication but employs OTC swaps with counterparties (Morgan Stanley Bank AG, Societe Generale) for currency hedging, which introduces counterparty risk and complexity. While the primary replication method is physical, the use of swaps for hedging purposes and the explicit mention of counterparty risk in the KIID and factsheet indicate complexity under MiFID II. The presence of OTC derivatives and the need to manage counterparty exposure make this a complex instrument despite its UCITS compliance and straightforward equity benchmark.",
    "confidence": 85,
    "counter_argument": "The ETF could be argued as non-complex due to its primary physical replication and straightforward equity index tracking. However, the use of OTC swaps for hedging introduces material counterparty risk and operational complexity, which are key indicators of complexity under MiFID II. The explicit disclosure of these risks in the KIID and factsheet further supports the complex classification.",
    "risk_level": 4,
    "benchmark_complexity": "low",
    "liquidity_risk": "moderate",
    "counterparty_risk": "high",
    "hedging_strategy": "daily currency hedging via OTC swaps"
}