{
    "fund_name": "iShares Spain Govt Bond UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Currency hedging using FX forward contracts",
        "Use of financial derivative instruments (FDIs) for direct investment purposes",
        "Counterparty risk from derivative counterparties"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication with some optimisation techniques and derivative usage for currency hedging and efficient portfolio management. While derivatives are used, they are not for leverage or complex strategies, and the overall structure remains transparent with a straightforward investment objective in Spanish government bonds. The risk profile is rated 4/7, which is moderate, and the fund is UCITS-compliant, indicating regulatory approval for retail investors. The use of derivatives is for hedging and efficient replication rather than creating complex exposure.",
    "confidence": 90,
    "counter_argument": "Some may argue that the use of derivatives for hedging and optimisation could indicate complexity, but under MiFID II, such usage is typically considered standard for efficient portfolio management and does not automatically trigger a 'complex' classification unless the derivatives create materially different risk profiles or require specialist knowledge to understand.",
    "final_reasoning": "The ETF is classified as non-complex because its derivative usage is for hedging and efficient replication, not for leverage or complex strategies. The overall structure is transparent, and the risk profile is moderate and easily understandable for retail investors."
}