{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": [
        "Swap-based replication",
        "Counterparty risk exposure",
        "ESG screening complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swap agreements to track the MSCI China A Inclusion Select Screened Index, which introduces counterparty risk. The KIID explicitly mentions derivative counterparty risk and the potential for losses if the swap counterparty fails to meet obligations. Additionally, the ESG screening methodology adds complexity to the underlying index construction. The fund's risk level is classified as 6 out of 7, indicating high volatility and potential for significant losses. The presence of swap agreements and the associated counterparty risks are key factors in determining this as a complex instrument under MiFID II.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "esg_screening": true,
    "benchmark_complexity": "moderate",
    "liquidity_risk": "moderate",
    "gearing": false,
    "structured_features": false,
    "capital_protection": false,
    "comprehension_warning": false,
    "additional_notes": "While the ETF does not use leverage or inverse strategies, the synthetic replication method and the complexity of the ESG-screened index contribute to its classification as a complex instrument. The counterparty risk associated with swap agreements is a significant factor under MiFID II rules."
}