{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Emerging markets complexity"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity beyond simple physical replication. The use of derivatives (swaps) for index tracking, combined with exposure to emerging markets, makes the risk profile more complex. The PRIIPs KID confirms the synthetic replication method and highlights counterparty risk as a key risk factor. The fund's risk category of 6 (out of 7) further supports the complexity classification. While the ETF is UCITS-compliant and does not use leverage or inverse strategies, the synthetic structure and counterparty risk are sufficient to classify it as complex under MiFID II.",
    "confidence": 90
}