{
    "fund_name": "iShares Smart City Infrastructure UCITS ETF (USD Acc)",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Thematic index with specific revenue filters (50%+ from smart city/infrastructure sectors)",
        "Optimized replication may include FDIs (financial derivative instruments) for direct investment purposes",
        "ESG screening criteria that may reduce investment universe",
        "Potential counterparty risk from derivative usage (though not primary strategy)"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication as its primary method and does not employ leverage, inverse strategies, or synthetic replication. While it mentions potential use of FDIs for direct investment purposes, this appears to be for optimization rather than core strategy. The thematic index is complex in its selection criteria but does not introduce structural complexity to the ETF itself. Counterparty risk is acknowledged but not a primary risk factor. The fund's risk profile (6/7) is higher due to sector concentration and emerging market exposure, but this does not equate to structural complexity. The PRIIPs KID does not contain a comprehension warning, further supporting the non-complex classification.",
    "confidence": 90,
    "counter_argument": "Some may argue the optimized replication and potential FDI usage could indicate complexity, but the KIID/PRIIPs documents emphasize physical replication as the primary method. The FDIs are likely used for minor adjustments rather than core strategy, and the fund's overall structure remains transparent and liquid.",
    "final_reasoning": "The ETF's complexity factors relate to its thematic focus and optimization techniques rather than structural or derivative-based complexity. Under MiFID II, this does not meet the threshold for a 'complex' classification."
}