{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using swaps",
        "Currency hedging with derivatives",
        "Complex index methodology (risk-aware selection)",
        "Emerging market sovereign debt exposure"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses synthetic replication via swaps for currency hedging and index tracking, which introduces counterparty risk and derivative exposure. While the underlying assets (emerging market sovereign bonds) are not inherently complex, the use of derivatives for replication and hedging, combined with the risk-aware index methodology, makes the structure more complex than a purely physically replicated ETF. The risk profile (category 5) and references to derivative-related risks in the KIID further support this classification. The fact that it's UCITS-compliant doesn't automatically make it non-complex under MiFID II, as UCITS rules focus on investor protection rather than MiFID II's complexity assessment.",
    "confidence": 85
}