{
    "type": "ETC",
    "ucits": false,
    "replication_method": "synthetic",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Complex structured product"
    ],
    "classification": "complex",
    "supporting_data": "The product is an open-end tracker certificate linked to the UBS CMCI Copper USD TR Index, which is a synthetic ETF (ETC) that does not use physical replication. The KIID explicitly states that the product is 'not simple and may be difficult to understand,' which is a strong indicator of complexity under MiFID II. The product uses a swap-based structure to replicate the index, exposing investors to counterparty risk. The KIID also mentions that the product is intended for 'clients with advanced knowledge of and/or experience with financial products,' further supporting its classification as complex. The risk indicator is rated 5 out of 7, indicating medium-high risk, and the product does not provide any capital protection. The PRIIPs KID and factsheet would likely contain additional details about the swap structure and counterparty risk, reinforcing the complexity assessment.",
    "confidence": 95
}