{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Counterparty risk exposure",
        "Unfunded swap structure"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco MSCI USA UCITS ETF uses unfunded swaps for synthetic replication, which introduces counterparty risk and complexity beyond physical replication. The KIID explicitly states the use of 'unfunded swaps' and mentions that the fund may purchase securities not contained in the index, relying on swap agreements to match index performance. The PRIIPs KID confirms the synthetic replication method and highlights counterparty risk as a material risk factor. While the fund does not use leverage or inverse strategies, the synthetic structure and swap-based replication are sufficient to classify it as complex under MiFID II. The fund's risk category (6) and the disclosure of counterparty risk further support this classification. The fact that the fund is UCITS-compliant does not negate the complexity introduced by the synthetic replication method.",
    "confidence": 90
}