{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Potential tracking error",
        "Emerging market complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via total return swaps with counterparties like Morgan Stanley and Societe Generale, which introduces counterparty risk. While the fund is UCITS-compliant and has no leverage, the use of derivatives for replication and the emerging market exposure make it complex under MiFID II. The KIID explicitly mentions counterparty risk and replication risk, which are key complexity indicators. The fact sheet confirms the synthetic replication method and highlights counterparty risk, further supporting the complex classification.",
    "confidence": 90
}